Technical Advisory Group for 

Biological Control Agents of 

Weeds Manual 
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Department of Agriculture. 

Second Edition Issued 2021 
Contents 

TAG-BCAW 

Manual 

Figures LOF-1-1

Tables LOT-1-1

Introduction 1-1-1

Technical Advisory Group 2-1-1

Introduction 2-1-1 

Charter 2-2-1 

Agencies and Organizations’ Perspectives 2-3-1 

TAG-BCAW Chair’s Perspective 2-4-1 

Petitions and Permitting 3-1-1

TAG-BCAW Flow Chart for Petitions for Field Release and Test Plant 

Lists 3-1-1 

APHIS Permitting Process 3-2-1 

Biological Control of Weeds 4-1-1

Introduction 4-1-1 

Identification and Characterization of Agents 4-2-1 

Host Specificity Testing of Arthropods 4-3-1 

Host Specificity Testing of Pathogens 4-4-1 

Format and Evaluation 5-1-1

Petitions for Field Release Format 5-1-1 

Petitions for Field Release Evaluation 5-2-1 

Test Plant List Format 5-3-1 

ESA Compliance 6-1-1

Section 7 Consultations 6-1-1 

Biological Assessments and Effects Determination 6-2-1 

TAG-BCAW Membership A-1-1

Directory A-1-1 

Forms B-1-1

10/2023-05 TAG-BCAW Manual TOC-1 
Contents 

NAPPO Standard C-1-1

Fish and Wildlife Service Offices D-1-1

Directory D-1-1 

Plant Classification System E-1-1

References F-1-1

Glossary Glossary-1-1

Index Index-1-1

TOC-2 TAG-BCAW Manual 10/2023-05 
Figures 

TAG-BCAW 

Manual 

Figure 3-1-1 TAG-BCAW Petition for Field Release or Test Plant List Flow 

Chart 3-1-2 

Figure B-1-1 Technical Advisory Group (TAG-BCAW) Reviewer’s Comment 

Sheet - Petition for Field Release of Biological Control Agents of 

Weeds (front) B-1-2 

Figure B-1-2 Technical Advisory Group (TAG-BCAW) Reviewer’s Comment 

Sheet - Petition for Field Release of Biological Control Agents of 

Weeds (back) B-1-3 

Figure B-1-3 TAG-BCAW Reviewer’s Comment Sheet for Test Host Plant 

Lists for Proposed Biological Control Agents of Weeds 

(front) B-1-5 

Figure B-1-4 TAG-BCAW Reviewer’s Comment Sheet for Test Host Plant 

Lists for Biological Control Agents of Weeds (back) B-1-6 

Figure B-1-5 PPQ Form 526, Application to Move Live Plant Pets or Noxious 

Weeds B-1-9 

Figure B-1-6 Example of PPQ Form 599, Import Label for Living Regulated 

Organisms (red and white shipping label) (adhesive label issued 

before September 9, 2014, but valid until expiration date on 

permit) B-1-11 

10/2023-05 TAG-BCAW Manual LOF-1 
Figures 

LOF-2 TAG-BCAW Manual 10/2023-05 
Tables 

TAG-BCAW 

Manual 

Table 1-1-1 Where to Report Problems With or Suggestions for the TAGBCAW Manual 1-1-9 

Table 4-2-1 National Collections for Specimens 4-2-9 

Table 5-2-1 Where to Find More Information About Target Weeds 5-2-3 

Table 5-2-2 Locating Biological Control Agent Information 5-2-4 

Table 5-2-3 Locating Biological Control Agent Information 5-2-4 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds 

Evaluation 5-2-5 

Table 5-2-5 TAG-BCAW Reviewer’s Overall Recommendation Checklist— 

Petitions for Field Release of Biological Control Agents of 

Weeds 5-2-17 

Table 5-3-1 References for Developing a Test Plant List 5-3-13 

Table 5-4-1 Where to Find More Target Weed Information 5-4-4 

Table 5-4-2 Evaluation Checklist for Test Plant Lists 5-4-5 

Table 5-4-3 Checklist for Reviewer’s Completion of Test Host Plant 

Lists 5-4-17 

Table 6-2-1 Effects Analysis and Agency Determination 6-2-7 

Table 6-2-2 Conservation Measures for Species Identified in 

Table 6-2-1 6-2-8 

Table A-1-1 TAG-BCAW Membership Directory A-1-1 

Table B-1-1 PPQ Form 599, Import Label for Living Regulated Organisms 

(red and white label) Mailing or Shipping (new plain paper 

(nongummed) or special adhesive (gummed) label issued starting September 9, 2014) B-1-11 

Table D-1-1 Directory of U.S. Fish and Wildlife Service (FWS) Regional 

Offices D-1-1 

10/2023-05 TAG-BCAW Manual LOT-1 
Tables 

LOT-2 TAG-BCAW Manual 10/2023-05 
Introduction Chapter 

1 

Contents 

Purpose 1-1-1 

Scope 1-1-2 

What the Manual Covers 1-1-2 

What the Manual Does Not Cover 1-1-3 

Authority 1-1-3 

Users 1-1-3 

Related Documents 1-1-3 

Authority 1-1-3 

Application 1-1-4 

Conventions 1-1-5 

Advisories 1-1-5 

Using the Manual 1-1-8 

Reporting Problems With or Suggestions for the Manual 1-1-9 

Manual Updates 1-1-10 

Ordering Manuals and Revisions 1-1-10 

Purpose 

The Introduction chapter of the Technical Advisory Group for Biological 

Control Agents of Weeds Manual (TAG-BCAW Manual) provides guidance for 

the technical advisory group and the scientific community, including 

petitioners and TAG-BCAW reviewers. 

The TAG-BCAW Manual serves the following functions: 

Information guide for other users 

Reference guide for preparing petitions 

Reference guide for preparing test plant lists 

Reference guide for reviewing and evaluating petitions for field release of 

biological control agents of weeds in the United States 

Reference guide for reviewing and evaluating test plant lists 

Training tool for orienting TAG-BCAW members 

10/2023-05 TAG-BCAW Manual 1-1-1 
Introduction 

Scope 

Scope 

What the Manual Covers 

The TAG-BCAW Manual is written specifically for researchers preparing and 

submitting petitions or test plant lists associated with the proposed release of 

biological control agents of weeds, and for TAG-BCAW members responsible 

for reviewing and evaluating submitted petitions and test plant lists. 

The manual contains the following chapters: 

Introduction 

Technical Advisory Group 

Petitions and Permitting 

Biological Control of Weeds 

Format and Evaluation 

ESA Compliance 

The Technical Advisory Group chapter provides new members with a history 

of the advisory group, its charter, and insight into the review process that the 

TAG-BCAW follows. 

The Petitions and Permitting chapter provides a flowchart of the petition 

process and information about APHIS’ process for petitioners to follow for 

obtaining permits. 

The Biological Control of Weeds chapter provides basic information about 

topics such as identification and characterization of biological control agents 

of weeds, host specificity, and testing methods. 

The Format and Evaluation chapter provides formats for petitions for field 

release and for test plant lists respectively. The checklists are for TAG-BCAW 

members to follow as they review petitions for field release of biological 

control agents of weeds and test plant lists. The chapter also provides the 

evaluation guidelines to facilitate the review, evaluation, and approval 

processes. TAG-BCAW members use these as they review test plant lists and 

petitions for field release of biological control agents of weeds. Throughout the 

evaluation guidelines, TAG-BCAW members are prompted to record their 

comments on a Reviewer's Comment Sheet. 

The ESA Compliance chapter provides an overview of Section 7 of the 

Endangered Species Act (ESA) and Fish and Wildlife Service’s role on TAGBCAW. Researchers and petitioners are encouraged to read this and the ESA. 

1-1-2 TAG-BCAW Manual 10/2023-05 
Introduction 

Users 

The manual contains appendices, a glossary, and an index. 

What the Manual Does Not Cover 

The manual does not cover the following: 

Approval for permits 

Approval for petitions 

Final decisions on the release of biological control agents of weeds 

Users 

The Technical Advisory Group for Biological Control Agents of Weeds Manual 

(TAW-BCAW Manual) is written for use by TAG-BCAW members and by 

petitioners. Parts of this manual may be referenced by others, such as experts 

within the Federal agencies represented on TAG-BCAW, researchers, external 

reviewers, university experts, foreign nationals who are involved in evaluating 

biological control agents, and members of international organizations, such as 

the North American Plant Protection Organization (NAPPO). 

The experience level of the TAG-BCAW Manual’s users will vary, but TAGBCAW members should fully understand and communicate their Agency’s or 

organization’s current perspective on biological control activities. 

Related Documents 

Authority 

Enabling legislation provides the authority to carry out the mission of 

protecting American agriculture from plant pests. Legislative Acts are the 

fundamental authority granted by Congress to the Secretary of Agriculture to 

promulgate regulations to protect American agriculture. The regulatory 

authority for taking the actions listed in this manual is contained in the Plant 

Protection Act (PPA). The PPA provides the authority to prohibit or restrict 

imports, exports, or interstate movement of biological control agents, plant 

pests, plant products, plants, noxious weeds, and means of conveyance. 

The regulatory authority for taking the actions listed in the manual are 

contained in the following: 

Endangered Species Act (ESA) (16 U.S.C. 1531 et. seq.) 

National Environmental Policy Act (NEPA) (42 U.S.C. 4321 et seq.) 

Plant Protection Act of 2000 (PPA) (7 U.S.C 7701 et. seq.) 

Coastal Zone Management Act (16 U.S.C. 1451 et. seq.) 

Executive Order 13112 (64 CFR 6184) for Invasive Species 

10/2023-05 TAG-BCAW Manual 1-1-3 
Introduction 

Application 

Plant Protection Act of 2000 

The Plant Protection Act of 2000 (7 U.S.C. 7701 et seq.) provides the 

Secretary of Agriculture with the authority to regulate “any enemy, antagonist, 

or competitor used to control a plant pest or noxious weed.” 

Cooperating Organizations 

The following are cooperating agencies, countries, and organizations for the 

TAG-BCAW Manual: 

Canada, Agriculture and Agri-Food Canada 

Mexico, SAGARPA-SENASIA-DGSV 

National Plant Board 

United States Department of Defense (USDOD), U.S. Army Corps of 

Engineers (COE) 

United States Environmental Protection Agency (EPA) 

United States Department of Agriculture (USDA), Agricultural Research 

Service (ARS) 

USDA, Animal and Plant Health Inspection Service (APHIS) 

USDA, Forest Service (FS) 

USDA, National Institute of Food and Agriculture (NIFA) 

USDA, Natural Resource Conservation Service 

United States Department of Interior (USDI), Bureau of Indian Affairs 

(BIA) 

USDI, Bureau of Land Management (BLM) 

USDI, Bureau of Reclamation (BR) 

USDI, Fish and Wildlife Service (FWS) 

USDI, National Park Service (NPS) 

USDI, U.S. Geological Survey (USGS) 

Weed Science Society of America (WSSA) 

Application 

This manual contains information for TAG-BCAW members to use as they 

review test plant lists and petitions for release. This manual contains 

instructions for petitioners to follow to prepare and submit a petition; and 

provides instructions for petitioners to follow to submit an application for a 

permit. 

1-1-4 TAG-BCAW Manual 10/2023-05 
Introduction 

Conventions 

Conventions 

Conventions are established by custom and are widely recognized and 

accepted. Major conventions used in this manual follow. 

Advisories 

Advisories are used throughout the manual to bring important information to 

your attention. Please carefully review each advisory. The definitions coincide 

with those of the American National Standards Institute (ANSI), and are in the 

format shown below. 

! DANGER 

DANGER indicates a hazardous situation which, if not avoided, will result in death 

or serious injury. 

! WARNING 

WARNING indicates a hazardous situation which, if not avoided, could result in 

death or serious injury. 

! CAUTION 

CAUTION indicates a hazardous situation which, if not avoided, could result in minor 

or moderate injury. 

NOTICE 

NOTICE is used to address practices not related to physical injury. 

SAFETY 

SAFETY is used to indicate specific safety-related instructions or procedures. 

Boldface 

Boldface type is used to emphasize important words throughout this manual. 

These words include: always, cannot, do not, does not, except, lacks, must, 

neither, never, no, nor, not, only, other than. 

10/2023-05 TAG-BCAW Manual 1-1-5 
Introduction 

Conventions 

Bullets 

Bulleted lists indicate there is no specific order to follow for the information 

listed. 

Change Bar 

A black change bar (see left margin) is used to indicate a change appearing on 

a revised page. Unfortunately change bars do not always appear when text is 

deleted. 

Contents 

Every chapter has a table of contents listing only the first- and second-level 

headings with the chapter section. 

Control Data 

Control data is located at the top and bottom of each page to help manual users 

keep track of where they are in the manual and to be aware of updates to 

specific chapters and appendixes in the manual. At the top of each page is the 

chapter title and first-level heading for that page. At the bottom of each page is 

the transmittal number (month, year, number), title of the manual, and page 

number. 

Examples 

Examples are used to clarify a point by applying to a real-world situation. 

EXAMPLE Examples are graphically-placed boxes within the text as a means of visually 

separating information from other information contained on the page. 

Examples appear in a box like this. 

Footnotes 

Footnotes comment on or cite a reference to text and are referenced by number. 

The footnotes used in this manual include general text footnotes, figure 

footnotes, and table footnotes. 

General text footnotes are located at the bottom of the page after a thin green 

line half the width of the page and flow numerically throughout a chapter. 

When space allows, figure and table footnotes are located directly below the 

associated figure or table. However, for multi-page tables and tables covering 

the entire length of a page, the footnote numbers and footnote text cannot be 

included on the same page. If a figure or table continues beyond one page, then 

the associated footnotes will appear on the page following the end of the figure 

or table. Each table’s footnotes are individually numbered, and will be 

indicated beginning with footnote number 1. 

1-1-6 TAG-BCAW Manual 10/2023-05 
Introduction 

Conventions 

Heading Levels 

Within each chapter and section there are up to four heading levels. The firstlevel heading is indicated by a horizontal line across both the left and right 

columns, and the heading follows directly below and across both columns. The 

second-level heading is in the right-hand column with the text beginning below 

and is subordinate to the first-level heading. The third-level heading is in the 

right-hand column with the text following below and is subordinate to the 

second-level heading. The fourth-level heading is followed by a period, is 

inside the right column, and is subordinate to the third-level heading. 

Hyperlinks to Figures, Headings, and Tables 

Figures, headings, and tables are cross-referenced in the body of the manual 

and are in blue hypertext in the on-line manual. 

EXAMPLE See Reporting Problems With or Suggestions for the Manual on 

page 1-9 to determine where to report problems with this manual. 

Indentations 

Content information, lengthy quotations, and entry requirements which are 

summarized from the Code of Federal Regulations, import permits, or policies 

are indented. 

Italics 

The following items are italicized throughout this manual: 

Cross-references to headings 

Publication names 

Scientific names of commodities 

Numbering Scheme 

A three-level numbering scheme is used in this manual for figures, pages, and 

tables. The first number represents the chapter. The second number represents 

the section. The third number represents the page, table, or figure. Dashes are 

used in numbering to differentiate from decimal points. 

10/2023-05 TAG-BCAW Manual 1-1-7 
 

 

Introduction 

Using the Manual 

Transmittal Number 

The transmittal number contains the month, year, and a consecutively-issued 

number (beginning with -01 for the first transmittal for each edition and 

increasing consecutively for each update to the edition). The transmittal 

number is only changed when a specific chapter, section, front matter, or back 

matter is updated. If no changes are made to a specific chapter or section, then 

the transmittal number for that chapter or section remains unchanged. The 

transmittal number only changes for the entire manual when a new edition is 

issued or changes are made to the entire manual. 

EXAMPLE 01/2021-01 is the transmittal number for this second edition and is 

located in the control data in the footer area of the pages in this 

manual. 

01 is the month the manual was issued 

2021 is the year the manual was issued 

-01 is the first transmittal for this second edition 

Using the Manual 

Review the contents of the manual to get a feel for the scope of the material 

covered. Glance through the section that you will be using, and familiarize 

yourself with the organization of the information. Use the table of contents 

which is listed on the first page of each chapter or section and some appendixes 

to find the information you need. If the table of contents is not specific enough, 

then use the index to find the topic and corresponding page number or use the 

pdf search feature. 

EXAMPLE To find information about APHIS’ perspective on the biological control of 

weeds in North America, see Animal and Plant Health Inspection Service 

(APHIS) on page 2-3-2. 

1-1-8 TAG-BCAW Manual 10/2023-05 
 

 

Introduction 

Using the Manual 

Reporting Problems With or Suggestions for the Manual 

Use Table 1-1-1 to determine where to report problems, disagreements, or 

improvements which directly affect the contents of the TAG-BCAW Manual. 

Table 1-1-1 Where to Report Problems With or Suggestions for the TAG-BCAW Manual 

If you: Then: 

Are not able to access the on-line manual CONTACT PPQ’s Manuals Unit by email 

PPQ.IRM.ISMU.Manuals.Feedback@usda.gov 

or call 240-529-0350 

Have a problem with the content of the manual 

that requires an answer 

CONTACT the TAG-BCAW Executive Secretary 

Mr. Gregg Goodman, TAG-BCAW Executive Secretary 

USDA-APHIS-PPQ 

4700 River Road, Unit 133, 4C-01.48 

Riverdale, MD 20737 

Email: gregg.b.goodman@usda.gov 

Phone:301-851-2074 

Fax: 301-734-5269 

Have a question with or suggestion for improving 

the content of the manual 

1. PRINT the Comment Sheet 

2. Write your suggestion 

3. SEND the completed comment sheet to the TAG-BCAW 

Executive Secretary by Email or U.S. Mail 

Mr. Gregg Goodman 

TAG-BCAW Executive Secretary 

USDA-APHIS-PPQ 

4700 River Road, Unit 133, 4C-01.48 

Riverdale, MD 20737 

Email: gregg.b.goodman@usda.gov 

Have a suggestion for improving the formatting 

(composition, design, layout), grammar, or spelling 

CONTACT PPQ’s Manuals Unit at 

PPQ.IRM.ISMU.Manuals.Feedback@usda.gov 

or call 240-529-0350 

10/2023-05 TAG-BCAW Manual 1-1-9 
Introduction 

Using the Manual 

Manual Updates 

The USDA-APHIS-PPQ Manuals Unit issues and maintains manuals 

electronically on the Manuals Unit Web site. 

Immediate update revisions to the manual are issued and distributed via email 

to CBP Agriculture Specialists, PPQ employees, current TAG-BCAW 

members, and subscribers to the USDA-APHIS Stakeholder Registry (go to 

the Manuals Updates/Import Inspection Manuals/ listed; and check the box for 

the Technical Advisory Group for Biological Control Agents of Weeds 

Manual). 

Each immediate update contains the following information: 

Link to access and download the on-line manual 

List of the revised pages 

Purpose of the revision(s) 

Transmittal number 

Ordering Manuals and Revisions 

Although using the on-line manuals is the preferred method, USDA-APHIS 

employees may order hard copies of manuals from the APHIS Printing, 

Distribution, Mail Center, and Copier Services Center in Riverdale, Maryland. 

Visit the Riverdale Print Shop Web site for detailed information and printing 

costs. The Manuals Unit is not responsible for printing costs. 

1-1-10 TAG-BCAW Manual 10/2023-05 
Technical Advisory Group 

Introduction 

Chapter 

2 

Contents 

Introduction 2-1-1 

Biological Control of Weeds 2-1-1 

History 2-1-2 

Subcommittee on Biological Control of Weeds 2-1-2 

Working Group 2-1-2 

Technical Advisory Group for Biological Control Agents of Weeds (TAGBCAW) 2-1-3 

Introduction 

The Introduction section of the Technical Advisory Group chapter provides 

information about the Technical Advisory Group for Biological Control 

Agents of Weeds (TAG-BCAW). 

Biological Control of Weeds 

Biological control can be defined as the deliberate use of natural enemies 

(competitors, parasites, pathogens, predators, and other organisms) to suppress 

and maintain populations of a target pest species (insects, mites, plant 

pathogens, and other pest organisms) below densities that cause economic and/ 

or environmental damage. 

Classical biological control of weeds consists of returning to the native range 

of the target weed, identifying its complex of natural enemies, testing 

extensively, and releasing one or more host specific, natural enemies to control 

the target weed. See Biological Control on page 4-1 for basic information. 

Many organizations are involved in searching, testing, and introducing 

potential biological control agents of weeds. Some of these organizations 

include the USDA Agricultural Research Service (ARS); the USDA Forest 

Service (FS); USGS Biological Resources Division; State departments of 

agriculture and universities; Agriculture and Agri-Food Canada, and CAB 

International. Within the United States, the importation and the release of 

biological control agents of weeds are regulated by USDA-APHIS because the 

agents may potentially present a plant pest risk. 

10/2023-05 TAG-BCAW Manual 2-1-1 
Technical Advisory Group 

History 

History 

Over the last 50 years, technical advisory groups have assisted researchers and 

regulatory agencies in evaluating proposed biological control agent 

introductions for biological control of weeds in the United States. 

Subcommittee on Biological Control of Weeds 

The Subcommittee on Biological Control of Weeds, the first advisory group, 

was established in 1957. The initial membership included representatives from 

the U.S. Department of the Interior’s (USDI) Bureau of Reclamation, Bureau 

of Land Management, and Fish and Wildlife Service; and from the U.S. 

Department of Agriculture’s (USDA) Forest Service and Agricultural Research 

Service. 

The initial responsibilities of the Subcommittee were as follows: 

Advise whether certain plant species targeted for biological control are 

universally regarded as weeds and recommend a course of action for 

situations involving conflicts of interest; and 

Recommend non-target plant species to be tested against the 

phytophagous organisms proposed for introduction. 

Through the 1960s the Subcommittee communicated primarily through 

correspondence, only meeting periodically to discuss biological control of 

weeds. An informal, reciprocal review of proposals began in 1962 between the 

United States and Canada. In 1969 the membership of the Subcommittee was 

expanded to include subject matter experts in plant taxonomy, ornamentals, 

and plant quarantine. At that time, the Bureau of Reclamation dropped its 

membership. 

Working Group 

In 1971 the Subcommittee on Biological Control of Weeds became known as 

the Working Group on Biological Control of Weeds. At this time, the Working 

Group began contacting Mexican officials concerning U.S. proposals. 

Canadian and Mexican comments were invited because the Working Group 

knew that an introduced organism recognizes no political boundaries and its 

introduction needed to be considered on a continental basis. Membership 

changed over the years because of reorganizations and the need to add 

members from the Environmental Protection Agency, Cooperative State 

Research, Education, and Extension Service (now the National Institute of 

Food and Agriculture), and the U.S. Army Corps of Engineers. 

Although the Subcommittee and Working Group were formed to provide 

advice primarily to the researchers, the Subcommittee’s and Working Group’s 

comments could be used by APHIS-PPQ in making decisions about issuing 

2-1-2 TAG-BCAW Manual 10/2023-05 
Technical Advisory Group 

History 

permits for importation or release. Responsibilities and procedures followed by 

the Working Group also changed over the years. 

Important additional responsibilities taken on by the Working Group were as 

follows: 

Review proposals to introduce candidate organisms into quarantine 

facilities; and 

Review adequacy of documentation supporting a proposed field release. 

Technical Advisory Group for Biological Control Agents of 

Weeds (TAG-BCAW) 

In January 1987, the Working Group was replaced by the Technical Advisory 

Group (TAG), now known as the Technical Advisory Group for Biological 

Control Agents of Weeds (TAG-BCAW). Then and now, TAG-BCAW 

functions under USDA-APHIS Plant Protection and Quarantine (APHISPPQ). Its membership continues to be voluntary and now must be in 

accordance with the Federal Advisory Committee Act (FACA). Membership is 

indefinite until members retire or their Agencies or organizations name 

someone else. TAG-BCAW is facilitated by an Executive Secretary from 

APHIS-PPQ. The TAG-BCAW Executive Secretary is not a voting member. 

The TAG-BCAW Chair is elected by its members for a 3-year, renewable term. 

Over the years, the TAG-BCAW has adapted to the needs of both researchers 

and regulatory agencies to better serve when they propose introducing an 

exotic organism into the United States for the biological control of weeds. 

Today the TAG-BCAW, with their scientific expertise, functions as a liaison to 

the biological control community and APHIS. The TAG-BCAW is able to 

advise potential petitioners about issues related to test plant lists and host 

specificity testing and research. 

APHIS-PPQ seeks the advice of and recommendations from the TAG-BCAW, 

and relies on the TAG-BCAW to provide scientifically-justified, unbiased 

recommendations. APHIS considers TAG-BCAW’s recommendations before 

performing a National Environmental Policy Act (NEPA) analysis; and then 

considers TAG-BCAW’s recommendations on proposed biological control 

agent of weeds before making a permit decision. 

The Plant Protection Act gives APHIS the authority to regulate the importation 

and release of biological control agents that may potentially present a plant 

pest risk. These regulations can be found in 7 CFR 330.200. 

The expectation is that researchers will involve the TAG-BCAW relatively 

early in a program to suggest the inclusion of certain test plants, perform, a 

10/2023-05 TAG-BCAW Manual 2-1-3 
Technical Advisory Group 

History 

NEPA analysis, identify conflicts of interest, and assess risk associated with a 

release. 

TAG-BCAW does not inform researchers of areas where a plant species may 

be considered a weed or a desirable plant. TAG-BCAW members do not make 

final decisions on the approval and permitted action for the release of 

biological control agents of weeds in North America. 

TAG-BCAW members only recommend to APHIS-PPQ that a proposed 

biological control agent be approved or denied permission for release, and 

recommend to petitioners specific action before they apply for a formal permit. 

NOTICE 

TAG-BCAW does not approve petitions or permits. See APHIS Permitting Process 

on page 3-1. 

In summary, the TAG-BCAW continues to provide APHIS-PPQ with a process 

in which petitions and test plant lists are reviewed by uninvolved parties from 

varying perspectives and concerns and varying scientific disciplines. TAGBCAW continues to serve as a science-based link between the research 

community and regulatory agencies, and to provide input from stakeholders. 

References 

Coulson, Jack R. 1992. The TAG: development, functions, procedures, and problems. In: Regulations and guidelines: critical issues in biological control, Proceedings of a USDA/CSRES 

national workshop; 53–60. 

Drea, John J., Jr. 1991. The philosophy, procedures, and cost of developing a classical biological control of weeds project. Natural Areas Journal 11(3); 143–147. 

Klingman, Dayton L.; Coulson, Jack R. 1983. Guidelines for introducing foreign organisms into 

the United States for the biological control of weeds. Bulletin of the Entomological Society of 

America 29(3); 55–61. 

2-1-4 TAG-BCAW Manual 10/2023-05 
Technical Advisory Group 

Charter 

Chapter 

2 

Contents 

Introduction 2-2-1 

Charter, Technical Advisory Group for Biological Control Agents of Weeds, 

October 1997, Revised 2010 2-2-1 

Mission 2-2-1 

Objectives 2-2-2 

Expectations 2-2-2 

Standard Operating Procedures 2-2-2 

Duties of TAG-BCAW Members 2-2-2 

Duties of the TAG-BCAW Chair 2-2-3 

Duties of the TAG-BCAW Executive Secretary 2-2-3 

Duties of USDA-APHIS-PPQ 2-2-4 

Annual Meeting 2-2-4 

Administration 2-2-4 

Federal Advisory Committee Act (FACA) 2-2-5 

Membership 2-2-5 

Introduction 

The Charter section of the Technical Advisory Group chapter describes the 

TAG-BCAW’s charter, mission, objectives, and standard operating procedures. 

Charter, Technical Advisory Group for Biological Control Agents of 

Weeds, October 1997, Revised 2010 

Mission 

To facilitate biological control of weeds in North America by providing 

guidance to researchers and recommendations to regulating agencies for or 

against the release of nonindigenous biological control agents of weeds. This is 

based on considerations of potential nontarget impacts, conflicts of interest, 

natural resources, agricultural production, and the Endangered Species Act 

(ESA) Threatened and Endangered Species List. 

10/2023-05 TAG-BCAW Manual 2-2-1 
Standard Operating Procedures 

Objectives 

Incorporate member agencies’ concerns and perspectives into planning 

biological control programs. 

Provide an exchange of views, information and advice for individuals who 

plan to ask various Federal and State regulatory agencies for permission to 

release these agents into the environment. 

Provide recommendations to APHIS-PPQ for use in making permitting 

decisions. 

Expectations 

Individuals planning to release a nonindigenous biological control agent 

should contact the TAG-BCAW early in the research program, particularly for 

species targeted for the first-time release of a biological control agent in the 

North America. 

TAG-BCAW members review two types of documents: the proposed plant list 

for host specificity testing (test plant list) and the petition for first-time field 

release of a nonindigenous organism. TAG-BCAW members may suggest 

inclusion of certain test plants, identify conflicts of interest, and assess 

potential risks associated with an environmental release. The person seeking 

permission to release a biological control agent into the environment addresses 

these different perspectives. The exchange of scientific information helps 

Federal regulatory officials evaluate potential effects of the biological control 

agent of weeds on target and nontarget plants in North America. 

Standard Operating Procedures 

Duties of TAG-BCAW Members 

Duties of TAG-BCAW members are as follows: 

Represent their Agency’s or organization’s interests by reviewing 

petitions from the organization’s current perspective on biological 

control; 

Review each petition to evaluate risk to agriculture, human health, and the 

environment; 

Identify and consult subject matter experts who are familiar with the 

taxonomy, biology, ecology, and other aspects of the organisms being 

considered for release and the target weed; 

Provide a written response consolidating their Agency’s or organization’s 

comments to the TAG-BCAW Executive Secretary within the deadline; 

Participate in the annual TAG-BCAW meeting; and 

2-2-2 TAG-BCAW Manual 10/2023-05 
Standard Operating Procedures 

Appoint an alternate within their organization to serve in the absence of 

the official member. 

Duties of the TAG-BCAW Chair 

The TAG-BCAW Chair is a TAG-BCAW member, elected by the TAG-BCAW 

membership to serve a 3-year term. The Chair may serve an unlimited number 

of terms. 

Duties of the TAG-BCAW Chair are as follows: 

Arrange and preside over meetings of TAG-BCAW; 

Assess all TAG-BCAW members’ continued involvement on the TAGBCAW to assist in keeping the respective organizations actively included 

on the TAG-BCAW; 

Contact TAG-BCAW Agencies and organizations to request a new 

qualified candidate who can represent that organization and replace nonactive TAG-BCAW members; 

Help build consensus among reviewers with divergent viewpoints. The 

Chair may call meetings or telephone conferences including outside 

specialists and the involved researcher; 

Maintain records of TAG-BCAW recommendations; and 

Review all recommendations of TAG-BCAW members and provide 

consolidated recommendations to the petitioner, TAG-BCAW members, 

appropriate officials in Canada and Mexico, APHIS TAG-BCAW 

Executive Secretary, and other interested parties. 

Duties of the TAG-BCAW Executive Secretary 

The TAG-BCAW Executive Secretary is an APHIS employee. 

Duties of the TAG-BCAW Executive Secretary are as follows: 

Assign due dates for reviews of all petitions and test plant lists; 

Compile petition and test plant list reviews and forward to the TAGBCAW Chair; 

Develop with the TAG-BCAW Chair, the TAG-BCAW annual meeting 

agenda, date, time, and location; 

Facilitate the distribution of petitions and test plant lists to TAG-BCAW 

members; 

Make all arrangements for the TAG-BCAW annual meeting (daily 

meeting space, hotel, shuttle, etc.); 

10/2023-05 TAG-BCAW Manual 2-2-3 
Standard Operating Procedures 

Maintain a filing system and perform other archival functions for TAGBCAW; 

Maintain the TAG-BCAW Web site and include APHIS permit decisions 

on the Internet; 

Receive and acknowledge receipt of all submitted petitions and test plant 

lists; 

Receive and respond to requests to extend review deadlines; 

Serve as the contact for Technical Advisory Group for Biological Control 

Agents of Weeds Manual (TAG-BCAW Manual) maintenance; and 

Transmit recommendations from the TAG-BCAW Chair to APHIS-PPQ. 

Duties of USDA-APHIS-PPQ 

Duties of USDA-APHIS-PPQ for petitions are as follows: 

Assure compliance with applicable statutes and regulations; 

Conduct training workshops as needed; 

Consider TAG-BCAW’s recommendations; 

Evaluate permit requests for movement of biological control agents of 

weeds by conducting a plant pest risk assessment; 

If a permit application is submitted, then APHIS may initiate the 

development of environmental and biological assessments when needed; 

May invite the researcher to submit a permit application; 

Perform the APHIS-PPQ permit process for movement of biological 

control agents of weeds and develop and communicate permitting policy 

pertaining to movement of these organisms; and 

When the TAG-BCAW recommends to APHIS to release an agent, then 

APHIS will review the recommendations and if reservations are noted 

ensure that these are addressed. 

Annual Meeting 

The TAG-BCAW Chair calls an annual meeting to evaluate the effectiveness of 

the TAG-BCAW, and to discuss controversial issues relating to biological 

control of weeds in North America. The TAG-BCAW membership elects a 

Chair every 3 years, during the annual meeting. 

Administration 

USDA-APHIS-PPQ will be responsible for the administrative maintenance of 

Federal Agencies’ representation. 

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Standard Operating Procedures 

Federal Advisory Committee Act (FACA) 

TAG-BCAW meetings shall be conducted in compliance with the Federal 

Advisory Committee Act (FACA). 

The law as amended (P.L. 104-4, Sec. 204), states the following: 

Meetings between State, Local, Tribal and Federal Officers - The Federal 

Advisory Committee Act (5 U.S.C. App.) shall not apply to actions in 

support of intergovernmental communications where: 

(1) Meetings are held exclusively between Federal officials and elected 

officers of State, local, and tribal governments (or their designated 

employees with authority to act on their behalf) acting in their official 

capacities; and 

(2) Such meetings are solely for the purposes of exchanging views, 

information, or advice relating to the management of implementation 

of Federal programs established pursuant to public law that explicitly 

or inherently share intergovernmental responsibilities or 

administration. 

FACA does not apply to meetings of TAG-BCAW because TAG-BCAW 

members include some Federal officials, some designated State officials, and 

some organizations. The TAG-BCAW members may contact non-Federal, 

State, local, or tribal parties to obtain information. Therefore, Canada, Mexico, 

researchers, industry, and professional or other societies may be contacted on 

an ad hoc basis. 

The TAG- BCAW focuses primarily on providing assistance to the individuals 

who will seek permits. Secondarily, TAG-BCAW provides a communication 

conduit within a scientific framework for APHIS. 

Membership 

APHIS will solicit one representative from each of the following Agencies: 

DOD, U.S. Army Corps of Engineers 

U.S. Environmental Protection Agency 

USDA, Animal and Plant Health Inspection Service 

USDA, Agricultural Research Service 

USDA, Forest Service 

USDA, National Institute of Food and Agriculture 

USDA, Natural Resource Conservation Service 

USDI, Bureau of Indian Affairs 

USDI, Bureau of Land Management 

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Standard Operating Procedures 

USDI, Bureau of Reclamation 

USDI, National Park Service 

USDI, U.S. Fish and Wildlife Service 

USDI, U.S. Geological Survey 

APHIS may solicit members who are State or Federal government employees 

(one each) from the following organizations: 

National Plant Board 

Weed Science Society of America 

Other Federal Agencies expressing interest in participation 

Each TAG-BCAW member is a representative of his/her respective Agency or 

organization. A TAG-BCAW member’s lack of participation or response to the 

TAG-BCAW petitions is of concern for all involved. Everyone’s best interests 

are served when all members are active. 

The TAG-BCAW Chair will assess each TAG-BCAW member’s continued 

involvement on the TAG-BCAW in trying to keep the respective Agencies or 

organizations as part of TAG-BCAW. If a current TAG-BCAW member is 

non-active, then the TAG-BCAW Chair has the prerogative to contact the 

represented Agency or organization and request a new qualified candidate to 

represent the Agency or organization and replace the non-active current TAGBCAW member. 

Furthermore, if an organization’s representative does not provide comments or 

the representative does not request an extension of a petition’s documented 

deadline, then the TAG-BCAW Chair interprets this to mean the organization 

does not oppose the petition. 

2-2-6 TAG-BCAW Manual 10/2023-05 
 

Technical Advisory Group 

Agencies and Organizations’ Perspectives 

Chapter 

2 

Contents 

Introduction 2-3-1 

U.S. Department of Agriculture (USDA) 2-3-2 

Animal and Plant Health Inspection Service (APHIS) 2-3-2 

Agricultural Research Service (ARS) 2-3-3 

Forest Service (FS) 2-3-3 

National Institute of Food and Agriculture (NIFA) 2-3-4 

U.S. Department of the Interior (USDI) 2-3-5 

Bureau of Indian Affairs (BIA) 2-3-5 

Bureau of Land Management (BLM) 2-3-5 

Bureau of Reclamation (BR) 2-3-6 

Fish and Wildlife Service (FWS) 2-3-7 

National Park Service (NPS) 2-3-7 

U.S. Geological Survey (USGS) 2-3-8 

Department of Defense (DOD) 2-3-9 

U.S. Army Corps of Engineers (COE) 2-3-9 

Environmental Protection Agency (EPA) 2-3-9 

U.S. Department of Agriculture (USDA) 2-3-2 

National Plant Board 2-3-9 

Canada: Agriculture and Agri-Food Canada (AAFC) 2-3-10 

Mexico: SAGARPA-SENASIA-DGSV 2-3-10 

Introduction 

The Agencies and Organizations’ section of the Technical Advisory Group 

chapter provides a brief summary of the perspective of each Agency and 

organization which has a representative on the TAG-BCAW. Members are 

responsible for reviewing and evaluating submitted petitions for release and 

test plant lists, and for recommending action based on their Agency’s or 

organization’s current perspective on biological control of weeds in North 

America. 

10/2023-05 TAG-BCAW Manual 2-3-1 
U.S. Department of Agriculture (USDA) 

U.S. Department of Agriculture (USDA) 

Animal and Plant Health Inspection Service (APHIS) 

The biological control activities within APHIS are performed under the 

regulatory authority of the Plant Protection Act of 2000, which states that, 

“biological control is often a desirable, low-risk means of ridding crops and 

other plants of plant pests and noxious weeds, and its use should be facilitated 

by the Department of Agriculture, other Federal Agencies, and States 

whenever feasible.” The Act also defines a biological control organism as any 

enemy, antagonist, or competitor used to control a plant pest or noxious weed. 

The authority to regulate biological control agents is dependent on the agents’ 

plant pest risks. 

The Animal Plant Health Inspection Service (APHIS) is involved in biological 

control activities that aim to safeguard American agriculture and ecosystems 

and minimize the economic and environmental impacts of nonindigenous 

pests, weeds, and plant diseases deemed of regulatory significance to APHIS, 

State departments of agriculture, tribal governments, and cooperators within 

the United States and American territories. 

APHIS biological control activities include the direct involvement of Plant 

Protection and Quarantine (PPQ) Field Operations (FO) personnel in 

distributing, releasing, and monitoring approved biological control agents for 

selected target pests. PPQ, through its FO and Policy Management (PM) units, 

also provides funds to Federal, State, university, local, and tribal project 

partners through cooperative trade agreements. Cooperators conduct target 

pest and biocontrol agent surveys, agent collections and releases, and pre- and 

post-release monitoring. The PPQ Center for Plant Health Science and 

Technology (CPHST) unit is also involved in biological control. CPHST 

scientists develop release and monitoring protocols, rear selected biological 

control agents, and incorporate biological control into integrated pest 

management strategies. CPHST provides funding for pre-release research and 

development efforts with potential biological control agents considered for 

U.S. release. Finally, the PPQ Pest Permitting Branch is responsible for 

approving or rejecting initial U.S. introduction and field release of biological 

control agents and for permitting subsequent interstate distribution and 

releases. All Agency units engage with other USDA Agencies, organizations, 

and a wide range of cooperators and customers to develop appropriate Agency 

legislation and regulations that meet U.S. needs for economical, efficient, and 

effective biological control programs of weeds. 

2-3-2 TAG-BCAW Manual 10/2023-05 
U.S. Department of Agriculture (USDA) 

Agricultural Research Service (ARS) 

The Agricultural Research Service (ARS) conducts research using classical 

and augmentative approaches to discover and develop arthropods and 

microbes as biological control components for integrated weed management 

systems in rangelands, croplands, noncroplands, and aquatic sites. ARS 

searches for and characterizes candidate host-specific biological control agents 

from foreign sites of origin of invading exotic target weeds. The Agency also 

discovers and develops endemic and foreign pathogens for inundative or 

inoculative releases against target weeds. ARS policy is to work with 

regulatory Agencies such as APHIS, Fish and Wildlife Service, and the 

Environmental Protection Agency to ensure that all of the Agency’s releases/ 

applications are in accordance with existing laws and regulations. 

Forest Service (FS) 

The Forest Service (FS) is charged with the management of approximately 190 

million acres of national forests and grasslands. The FS recognizes that the 

invasion of exotic plants is a key threat to continued existence of vulnerable 

native species, and to the integrity and healthy functioning of unique habitats. 

Exotic weeds also are a major problem and interfere with the FS’ effective 

management, compromise productivity, and impede the public’s enjoyment of 

these lands. 

To control these invaders, vegetation management personnel have available to 

them a wide range of tools from which they must select those that best fit the 

area, the targeted weed, and local management goals. However, FS recognizes 

that once a weed has become widely distributed, most conventional 

management tools provide only localized relief or containment. Biological 

control is usually the only realistic approach for many weed infestations. FS is 

supportive of vegetation management personnel to evaluate the feasibility of 

using weed biological control. When suitable approved biological control 

agents are available, managers are encouraged to add them as a control strategy 

in integrated weed management programs. 

When external researchers are testing new biological control agents for weeds 

that also affect FS lands, the FS actively encourages and supports their 

research through funding, providing experimental release plots, and 

participating in joint development programs. When weeds of concern to FS are 

not being targeted by other research agencies, FS researchers may initiate the 

search for, testing of, and importation of biological control agents. 

10/2023-05 TAG-BCAW Manual 2-3-3 
U.S. Department of Agriculture (USDA) 

National Institute of Food and Agriculture (NIFA) 

The Land Grant University System and the National Institute of Food and 

Agriculture (NIFA) have fundamental responsibility for discovering, 

developing, implementing, and extending technology in support of American 

agriculture and in concert with America’s natural resources. With a 

Congressional mandate in each State to support agriculture in cooperation with 

USDA and other Agencies, scientists within the Land Grant University System 

are greatly involved in the development of pest management strategies and 

programs for implementation in agricultural, forest, pasture, rangeland, and 

aquatic and urban environments, including natural and modified systems. This 

diverse mission also includes the conduct of biological and ecological research 

in these environments, which often serves as the baseline for development of 

applied problem-solving research and education efforts. 

Among the assets in research expertise which reside within the NIFAsupported Agricultural Experiment Station System, are disciplines that directly 

support biological control of weeds. Botany, plant ecology, land conservation 

and taxonomic studies in plants, animals, and microbes are among the many 

components of that expertise. 

An additional component of NIFA is the development and delivery of 

information in support of biological control and other integrated pest 

management (IPM) strategies. This educational and implementation system 

provides support to the public and private sectors who are affected by 

biological control of weeds, as well as the weed problems themselves. 

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U.S. Department of the Interior (USDI) 

U.S. Department of the Interior (USDI) 

Bureau of Indian Affairs (BIA) 

The Bureau of Indian Affairs (BIA) has responsibility for approximately 56 

million acres of Indian trust land (land held in trust by the United States for 

various Indian tribes and individuals). These trust lands are located within 326 

reservations (i.e., pueblos, rancheros, missions, villages, communities, etc.). At 

present, there are 565 Federally recognized American Indian and Alaska 

Native tribes and villages. 

Indian lands exist in all major ecosystems, from the Florida Everglades to the 

Alaskan Tundra, from hardwood forests to the Pacific rainforest, from the 

Sonoran Desert scrub to the Great Plains grassland, and include irrigated and 

dry cropland. These lands have been affected by the entire range of invasive 

species known in North America. 

The BIA and/or tribal governments operate a noxious weed control program on 

a number of these Reservations. Currently, herbicides are the tool of greatest 

use. However, the use of herbicides is judicious due to Native American 

concerns regarding their environment. More recently integrated noxious weed 

control has been emphasized, including the use of biological control agents. 

Although success using biological control agents has been noted, insurance of 

host specificity remains a concern of tribal governments and their constituents. 

Biological control is a welcomed addition to other noxious weed control tools. 

Nonetheless plants of economic, cultural, and medicinal value must be 

protected from off-target damage by biological control agents. 

Bureau of Land Management (BLM) 

The Bureau of Land Management (BLM) is responsible for carrying out a 

variety of programs for the management and conservation of resources on 253 

million surface acres, as well as 700 million acres of subsurface mineral estate. 

Most of the public lands are located in the Western United States, including 

Alaska. Public lands make up about 13 percent of the total land surface of the 

United States and more than 40 percent of all land managed by the Federal 

Government. The public lands are characterized predominantly by extensive 

grassland, forest, high mountain, arctic tundra, and desert landscapes. The 

BLM manages multiple resources and uses, including energy and minerals; 

timber; forage; recreation; wild horse and burro herds; fish and wildlife 

habitat; wilderness areas; and archaeological, paleontological, and historical 

sites. These multiple uses create surface disturbances exposing the public lands 

to invasive and noxious weeds. As such, the BLM uses biological control of 

weeds as a component of its integrated weed management program. The policy 

and use of biological controls are in BLM Manual 9014 where BLM’s policy is 

stated as follows: 

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U.S. Department of the Interior (USDI) 

Encourage the use of parasites, predators, and pathogens in integrated pest 

management programs to reduce pest organism populations to meet 

management objectives. This may include the use of domestic livestock 

to manage vegetation; 

Participate in cooperative integrated pest management programs in areawide efforts; 

Support efforts to develop new biological control agents to the level 

possible as one of the tools in a balanced integrated pest management 

program; and 

Collect and quantify all inventory and monitoring data for all pest 

management efforts and evaluate the success of failure of them. 

A Memorandum of Understanding exists between the BLM and APHIS which 

describes the interaction between these two agencies and National 

Environmental Policy Act compliance conditions. Prior to the release of an 

approved biological control agent, each State’s State Office must examine the 

practitioner’s Biological Control Agent Release Proposal (BCARP), which is 

notification of a planned release. Once an agent has been released, a Biological 

Control Release Record must be filled out within 24 hours after release and 

kept on record for a minimum of 7 years. All BLM Field Offices submit a 

comprehensive Integrated Pest Management report to their State Office each 

year. Final reports are then compiled and reviewed at the National Office. 

These precautions ensure that only approved biological control agents are 

released and those releases are continually monitored to evaluate efficacy over 

time 

Bureau of Reclamation (BR) 

The policy of the Bureau of Reclamation (BR) is to implement integrated pest 

management (IPM) for the control and management of pests and invasive 

species. As defined by the Federal Insecticide, Fungicide, and Rodenticide 

Act, and amended by the Food Quality Protection Act of 1996, “Integrated 

Pest Management is a sustainable approach to managing pests by combining 

biological, cultural, physical, and chemical tools in a way that minimizes 

economic, health, and environmental risks,” and “Federal agencies shall use 

Integrated Pest Management techniques in carrying out pest management 

activities and shall promote Integrated Pest Management through procurement 

and regulatory policies, and other activities.” 

Reclamation views biological control as an important tool in the IPM toolbox. 

Only by using the combined suite of IPM tools, including biological control, 

can pests and invasive plant species be successfully controlled. In addition, the 

TAG-BCAW is a vital component in a reviewable and transparent process 

during the evaluation of proposed biological control agents of weeds. 

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U.S. Department of the Interior (USDI) 

Fish and Wildlife Service (FWS) 

The Fish and Wildlife Service (FWS) strongly supports the development and 

legal and responsible use of appropriate, safe, and effective biological control 

agents on nuisance nonindigenous or invasive species. As the basis for 

approval, biological control organisms and strategies for their use must have 

undergone careful, comprehensive, and transparent testing and evaluation 

throughout their potential range to ensure their host specificity and determine 

their effects on all nontarget organisms, especially Federally-listed species or 

those considered for designation under the Endangered Species Act (ESA). 

Biocontrol organisms imported into, transported within, and released into the 

United States should be free of pathogens or parasites, so as not to 

unintentionally introduce other nonindigenous species. Additionally, the media 

used to ship biocontrol organisms must not include other nonindigenous 

organisms. Approval must involve open public review, as well as scientific 

peer review of test results, environmental risk assessment, and other applicable 

analyses. If biocontrol organisms are the most effective and appropriate means 

available, then they should be used on National Wildlife Refuges and other 

lands and waters under the jurisdiction of the Service. 

National Park Service (NPS) 

The National Park Service (NPS) relies on an integrated pest management 

(IPM) approach to manage pest species. The NPS considers biological control 

an important tool in an IPM strategy. In addition, the NPS management 

policies recognize the use of biological control agents on NPS lands as one of 

the limited reasons for releasing non-native organisms on NPS lands. 

However, the use of biological control agents should be targeted towards nonnative species. In that regard, biological control agents must be thoroughly and 

scientifically tested as to their host specificity, safety, and potential effects 

upon nontarget organisms before release. Biological control agents should be 

free of parasites and pathogens to reduce the risk of introducing additional 

non-native species into the United States and creating additional pest 

management problems. The results of pre-release testing of biological control 

agents must receive critical scientific peer review as well as public review and 

comment before agents are released. 

Biological control is a welcome addition to other noxious weed control tools. 

Nonetheless, plants of economic, cultural, and medicinal value must be 

protected from off-target damage by biological control agents. 

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U.S. Department of the Interior (USDI) 

U.S. Geological Survey (USGS) 

The United States Geological Survey (USGS) conducts investigations of nonnative invasive plants, animals, and disease organisms, including their biology 

and ecology, vectors and factors in their spread, and their effects on terrestrial 

and aquatic ecosystems and native biota. The USGS has capabilities in the 

development and evaluation of methodologies and technologies for early 

detection of non-native invasive species (NIS), monitoring of invasions, 

assessment of alternative control methods, and management of NIS, including 

restoration of impacted habitats. Particular emphasis is on improving the 

capabilities of Federal land managers to address threats from NIS. 

Through its research centers and cooperating universities, USGS conducts 

research on potential biocontrol agents for selected nonnative plants that are 

highly invasive in natural ecosystems (e.g., Miconia and strawberry guava in 

Hawaii). This research frequently includes international collaboration in 

locating, testing, and assessing potential biological control agents. 

In reviewing petitions for release of biocontrol agents, USGS focuses on the 

appropriateness of the research methodology, post-release monitoring, and the 

potential biological and ecological effects of proposed control agents. In 

reviewing test plant lists, the emphasis is on helping to ensure adequate 

screening of nontarget native species. 

2-3-8 TAG-BCAW Manual 10/2023-05 
 

Department of Defense (DOD) 

Department of Defense (DOD) 

U.S. Army Corps of Engineers (COE) 

One of the main missions of the Army Corps of Engineers (COE) is to 

maintain navigable waterways in the United States. This requires not only 

overseeing the actual channels, but also water bodies influencing navigable 

waterways. Exotic vegetation often impedes the operation of the waterways 

and requires extensive management operations. Biological control technology 

is a key component utilized in our integrated management approach for these 

waterways. In addition, the Department of Defense (DOD) and Army Corps of 

Engineers (COE) are stewards of a wide range of habitats found on their 

installations and facilities. Maintaining these natural plant communities is a 

high priority since many are unique habitats. Petitions are reviewed to ensure 

that the missions of DOD organizations are not negatively impacted by 

introductions of plant biological control agents. 

Environmental Protection Agency (EPA) 

The Environment Protection Agency (EPA) perceives the biological control of 

weeds as valuable in reducing risks from pesticides. EPA also views the 

biological control of weeds as a vital part of integrated pest management. 

National Plant Board 

The National Plant Board is made up of the principal plant pest regulatory 

officials of each of the 50 States. State officials review proposed introductions 

of live insects, including biological control agents. USDA’s permit (PPQ Form 

526, Application to Move Live Plant Pests or Noxious Weeds) requires 

approval from both the receiving State and USDA. The National Plant Board’s 

representation on TAG-BCAW facilitates this approval process and keeps all 

stakeholders involved from the beginning. 

Weed Science Society of America 

Members of the Weed Science Society of America (WSSA) are committed to 

the reduction of herbicide use through adoption of integrated weed 

management. WSSA views all forms of biological control as important tools 

for prevention of economic loss due to weeds. Although profitable agriculture 

is the major focus, reduction of negative impacts on the environment due to 

agriculture is an important consideration in the selection of weed management 

tools. 

10/2023-05 TAG-BCAW Manual 2-3-9 
Canada: Agriculture and Agri-Food Canada (AAFC) 

Canada: Agriculture and Agri-Food Canada (AAFC) 

Agriculture’s trend toward alternative solutions to chemical pesticides has led 

to an increasing use of biocontrol agents. Agriculture and Agri-Food Canada 

has a long-term commitment to sustainable agriculture via the safe importation 

and release of biocontrol agents of weeds. This commitment has produced 

several success stories which in turn have lessened Canada’s dependency on 

chemical pesticides and taken us in the direction of a cleaner environment. Part 

and parcel with Canada’s success and safety record is its continuing 

association with TAG-BCAW. 

Mexico: SAGARPA-SENASIA-DGSV 

Mexican participation in TAG-BCAW has been very useful because biological 

control of weeds is in development in Mexico. Some weeds are common to 

Mexico, Canada, and the United States; and cooperative projects could be 

carried out. A greater number of agents to be imported into Mexico is 

expected. 

Plants that are considered weeds in one country may not be considered weeds 

in another country. Given this, possible conflict of interests and impact on 

nontarget plants are the main concerns of Mexico. Target weed information 

must be reviewed to focus especially on the beneficial uses in Mexico and the 

impact on Mexican endangered and threatened species. 

2-3-10 TAG-BCAW Manual 10/2023-05 
Technical Advisory Group 

TAG-BCAW Chair’s Perspective 

Chapter 

2 

Contents 

Introduction 2-4-1 

TAG-BCAW Chair’s Concept 2-4-1 

Introduction 

The TAG-BCAW Chair’s Perspective section of the Technical Advisory Group 

chapter provides the steps the current TAG-BCAW Chair follows when 

reviewing a petition for release of a proposed biological control agent of weeds 

and for examining each reviewer's comments and recommendations; and the 

Chair’s overall concept for the TAG-BCAW and for making the final TAGBCAW recommendation for a petition. 

TAG-BCAW Chair’s Concept 

The TAG-BCAW Chair uses his general understanding of and ideas about how 

TAG-BCAW helps facilitate the use of proposed biological control agents of 

weeds in the environment, and specifically about his role as Chair of TAGBCAW. 

The petitions that receive mixed recommendations (some recommended 

release; some recommended release with reservations; some do not 

recommend release) are the hardest to evaluate. Often this situation is 

compounded when only a few members have reviewed the petition and 

submitted a recommendation. 

In general, TAG-BCAW should take a conservative stance in its 

recommendations. Determining if the proposed biological control agent of 

weeds may present a plant pest risk is the key issue. Once a biological control 

agent of weeds is released, it is difficult to control or manage the organism if 

the need should arise. 

The overall concept to make the final TAG-BCAW recommendation is, “How 

confident are we in the testing conducted and the information presented to 

recommend a proposed biological control agent of weeds for release into the 

environment?” 

10/2023-05 TAG-BCAW Manual 2-4-1 
TAG-BCAW Chair’s Evaluation Procedures 

TAG-BCAW Chair’s Evaluation Procedures 

Before reviewing each petition as the TAG-BCAW Chair, first review each 

petition from the perspective of a member representing his or her Agency (for 

the current TAG-BCAW Chair, the U.S. Army Corps of Engineers). 

Then as the TAG-BCAW Chair, evaluate each petition as follows: 

1. Look over all the responses other members of TAG-BCAW have 

submitted. 

2. Determine how many responses were submitted. 

3. Determine each member’s action: 

A. Recommend without reservations. 

B. Recommended with reservations. 

C. Not recommended. 

4. Examine each Reviewer’s Comment Sheet; and make notes on the key 

points each reviewer has made—both negative and positive. Look for 

similarities in the comments among reviewers. 

5. Review the notes of negative and positive points made by all the reviewers; 

examine each point in detail; and verify the comments made (i.e., “four 

larvae developed into adults when feeding on a particular plant,” or “No 

endangered plant species from the Northwest were tested”). 

6. Eliminate comments that are invalid or inconsistent with the data 

presented. May discuss these points with the reviewer to ensure a full 

understanding of his/her comments. 

A. The majority of points and concerns raised by reviewers are related to 

host specificity tests and the impact on nontarget plants. Address these 

comments first, along with the environmental impacts. 

B. When correct and valid points are made about a particular test, examine 

the petition to determine if additional information has been presented 

that would explain the comment (i.e., “feeding on a nontarget plant 

only occurred when the larvae were artificially placed inside the stem 

of the plant”). 

C. Taxonomic issues are always of concern. The TAG-BCAW members 

need to know what biological control agent is being tested and what 

weed is being targeted. When there is a concern about the taxonomic 

information, you may seek additional reviews from a recognized 

authority. Often taxonomic issues are raised by a taxonomic authority 

on the particular group. Sometimes taxonomic issues develop when the 

researcher is substituting one plant for a threatened or endangered one, 

2-4-2 TAG-BCAW Manual 10/2023-05 
TAG-BCAW Chair’s Evaluation Procedures 

which often requires getting additional information to validate or refute 

concerns. 

D. Comments on petitions for release that address points outside of TAGBCAW’s charge hold little weight (i.e., “since research funding for 

biological control is scarce, I feel that the researcher should devote his 

efforts to studying another target plant”). TAG-BCAW is concerned 

with the use of the proposed biological control agent of weeds and is 

not concerned with setting research priorities. 

7. If a reviewer’s comments are partially correct and may not be completely 

valid, then attempt to have the reviewer and the researcher discuss the 

concern. 

8. If some of the points cannot be resolved after deliberations and discussions 

between the researcher and the reviewer, then begin weighing the factors 

that are in contention. Often, reviewing the entire petition is useful when 

there are mixed views from the researchers. 

Is there a concern with plant pest risk to nontarget plants? 

Does the host specificity test cover a reasonable representation of the 

species identified on the test plant list? 

Is there a problem with taxonomy? 

Has this proposed biological control agent of weeds been reviewed 

previously? If so, what were the points that caused the proposed 

biological control agent of weeds not to be recommended? 

Has the researcher addressed previous TAG-BCAW questions? 

Does the researcher appear to be concerned and conscientious in the 

studies? 

9. After re-examining all the significant questions that are unresolved, 

recommend an action from TAG-BCAW that you believe you can justify. 

10. Write a letter to APHIS-PPQ and include the following: 

A. If the recommendation is to release, then include key points about the 

reason for the recommendation. Identify the minor points or problems 

that the researcher should address with the reviewer or APHIS before a 

release is made. 

B. If the recommendation is not to release, then include key reasons for 

the recommendation, such as the following: 

Recommend tests that may answer and resolve the questions 

raised; 

Attempt to develop a list of major concerns or questions that 

caused this recommendation; and 

10/2023-05 TAG-BCAW Manual 2-4-3 
TAG-BCAW Chair’s Evaluation Procedures 

Indicate that the researcher and the reviewers should directly 

discuss the points further. 

11. Provide copies of the letter (sent to APHIS-PPQ) to the researcher, TAGBCAW members, and other interested parties. 

12. TAG-BCAW’s response to APHIS is just a recommendation and is not a 

final decision. The recommendation of TAG-BCAW is not a majority rule 

verdict; that is, if eight reviewers recommend release and four reviewers 

recommend not to release, then TAG-BCAW’s recommendation is not 

necessarily to release. In addition, unresolved comments from a single 

reviewer recommending that a proposed biological control agent of weeds 

not be released does not mean that TAG-BCAW will recommend against 

release. 

2-4-4 TAG-BCAW Manual 10/2023-05 
 

Chapter 

3 Petitions and Permitting 

TAG-BCAW Flow Chart for Petitions for Field 

Release and Test Plant Lists 

Contents 

Introduction 3-1-1 

TAG-BCAW Petitions for Field Release and Test Plant Lists Flow Chart 

3-1-2 

Introduction 

The TAG-BCAW Flow Chart for Petitions for Field Release and Test Plant 

Lists section of the Petitions and Permitting chapter provides a flow chart for 

the documentation flow of petitions and test plant lists. 

NOTICE 

The Technical Advisory Group for Biological Control Agents of Weeds (TAG-BCAW) 

Chair consolidates recommendations that are received from TAG-BCAW members. 

The TAG-BCAW Manual provides an understanding of how the TAG-BCAW Chair 

reaches a final TAG-BCAW recommendation. 

The Technical Advisory Group for Biological Control Agents of Weeds’ 

(TAG-BCAW) entire review process is driven by the APHIS permitting 

process (see Permitting Process for Weed Biological Agents on page 3-2-2 for 

more information). 

10/2023-05 TAG-BCAW Manual 3-1-1 
 

Petitions and Permitting 

TAG-BCAW Petitions for Field Release and Test Plant Lists Flow Chart 

TAG-BCAW Petitions for Field Release and Test Plant Lists Flow 

Chart 

Continue to the flow chart in Figure 3-1-1. 

Petitioner 

May contact and consult with U.S. Fish and Wildlife Service for advice and input 

Prepares petition for Test Plant List or Field Release 

Sends petition to USDA-APHIS-PPQ TAG-BCAW Executive Secretary 

TAG-BCAW Executive Secretary 

Acknowledges receipt of the petition to the petitioner 

Establishes time lines 

Sends Petition Review Sheets to TAG-BCAW members 

Generates hard copy folders of petition to file 

Sends reminders to TAG-BCAW members 

Responds to TAG-BCAW members’ and Petitioner’s questions 

Filters information through the TAG-BCAW system 

TAG-BCAW Executive Secretary 

Confirms receipt of TAG-BCAW Reviewers sheets 

Sends compiled reviews to TAG-BCAW Chair 

Arranges conference calls to discuss issues with petition 

Logs and files petition 

TAG-BCAW Chair 

Consolidates recommendations 

Submits TAG-BCAW recommendations to TAG Executive Secretary and 

Petitioner 

TAG-BCAW Members 

Review and evaluate the petition, including Endangered Species Act 

May send to subject matter experts for evaluation 

Synthesize comments from subject matter experts (SME) 

Submit comments and recommendations to TAG-BCAW Executive Secretary 

Subject Matter Experts 

(SME) 

Evaluate petition 

Send evaluation 

to 

TAG-BCAW 

member 

TAG-BCAW Executive Secretary 

Sends TAG-BCAW recommendations in letter to APHIS-PPQ 

Files petition and letter to USDA-APHIS 

USDA-APHIS 

Evaluates the 

recommendations for 

acceptance 

Petitioner 

Submits application 

for permit through the 

ePermits system 

(see chapter 3-2 TAGBCAW Manual) 

NO 

Petitioner 

Conducts more 

research 

Resubmits test 

plant list or 

petition OR 

Discontinues 

effort 

YES 

USDA-APHIS 

Acknowledges receipt of TAG-BCAW recommendations 

Figure 3-1-1 TAG-BCAW Petition for Field Release or Test Plant List Flow Chart 

3-1-2 TAG-BCAW Manual 10/2023-05 
Petitions and Permitting 

APHIS Permitting Process 

Chapter 

3 

Content 

Introduction 3-2-1 

Permitting Process for Weed Biological Agents 3-2-2 

Step 1: Early Input 3-2-2 

Step 2: Applying for APHIS Permits for Importation 3-2-3 

Step 3: APHIS Responses to the Recommendation Letter from the TAGBCAW Chair 3-2-5 

Step 4: Environmental Compliance in Support of Petition for Release 

3-2-6 

Step 5: Compliance With Executive Order 13175 3-2-8 

Introduction 

The APHIS Permitting Process section of the Petitions and Permitting chapter 

provides information about APHIS’ role in each step of the review process for 

petitions submitted to the TAG-BCAW for the release of proposed biological 

control agents of weeds, and the flow of documents used by APHIS when 

considering whether to issue a permit for the release of such nonindigenous 

organisms. 

APHIS has authority to regulate the importation and interstate movement and 

release of biological control organisms (because they may potentially present a 

plant pest risk), noxious weeds, and plant pests under the Plant Protection Act 

of 2000. APHIS regulates the movement of these organisms in order to prevent 

the dissemination of plant pests or noxious weeds. These regulations may be 

found in the Code of Federal Regulations Chapter 7 Part 330. 

10/2023-05 TAG-BCAW Manual 3-2-1 
Permitting Process for Weed Biological Agents 

Permitting Process for Weed Biological Agents 

The Plant Protection Act of 2000 (7 U.S.C. 7701 et seq.) provides the 

Secretary of Agriculture with the authority to regulate “any enemy, antagonist, 

or competitor used to control a plant pest or noxious weed” that poses a 

potential plant pest risk. APHIS regulates biocontrol organisms because they 

are plant pests. Before issuing a permit to release a biocontrol organism into 

the environment, APHIS must comply with the National Environmental Policy 

Act (NEPA) (42 U.S.C. 4321 et seq.), the Endangered Species Act (ESA) (16 

U.S.C. 1531 et seq.), and Executive Orders (EO) 13112 (64 FR 6183) for 

Invasive Species and EO 12898 “Federal Actions to Address Environmental 

Justice in Minority Populations and Low-income Populations.” 

TAG-BCAW petitioners may refer to the following pages that describe the 

content and flow of documents used by APHIS to meet the requirements of the 

Acts and Executive Orders which includes APHIS’ responsibility for the 

issuance of such permits. An understanding of the various documents APHIS 

prepares and or reviews conducted should help to clarify this process. 

Step 1: Early Input 

Researchers should submit a proposed test plant list to the Technical Advisory 

Group for Biological Control Agents of Weeds (TAG-BCAW) whether or not a 

proposed biological control agent has yet been identified. The TAG-BCAW, an 

interagency group, was established to advise weed biological control 

researchers and to provide the APHIS-PPQ Pest Permitting Branch with a 

recommendation on the proposed Federal action, issuance of a permit 

authorizing release to the environment. At this early stage of the review 

process, TAG-BCAW makes recommendations on the target weed choices and 

comments on the proposed test plant list for host specificity testing. 

Both TAG-BCAW reviewers and researchers should review Federal and State 

lists of threatened and endangered species prior to host specificity testing. All 

threatened and endangered species should be considered when designing the 

test plant list. Candidate species and species proposed for listing should also be 

considered because they may be listed at any time. Web sites to obtain 

information on listed species include http://ecos.fws.gov/tess_public/ and 

http://ecos.fws.gov/ecos/indexPublic.do. Even though a U.S. Fish and Wildlife 

Service (USFWS) representative participates on the TAG-BCAW review 

panel, this does not substitute for the ESA consultation process. 

Petitioners are encouraged to contact the regional offices and local field offices 

of the USFWS in the areas where the target weed is located, prior to and during 

the host testing phase in order to obtain advice and guidance regarding any 

threatened, endangered, or proposed species. The USFWS can also provide 

3-2-2 TAG-BCAW Manual 10/2023-05 
Permitting Process for Weed Biological Agents 

guidance regarding obtaining seeds or samples of these plants or related 

species that can serve as surrogates for these species. 

Step 2: Applying for APHIS Permits for Importation 

Permits are required from APHIS for any of the following situations: 

Importation of live biological control organisms into the United States and 

its Territories (see PPQ 526 Permit for Importation); 

Interstate movement of live biological control organisms (includes 

movement between any State, territory and the District of Columbia) 

(see PPQ 526 Permit for Interstate Movement on page 3-4); 

Retaining live biological control organisms in containment facilities after 

expiration of a permit (see PPQ 526 Permit for Continued Curation on 

page 3-4); and 

Movement of any live biological control organism from the confines of a 

containment facility to any other containment facility or for 

environmental release (see PPQ 526 Permit for Removal from 

Containment on page 3-4). 

All conditions of any permit, including all authorizations and restrictions, 

remain binding as long as the permit is valid and prior to expiry. Revocation or 

expiration of any permit requiring containment for the regulated organisms 

requires devitalization or destruction of all organisms regulated by that permit, 

or a new permit for the organisms. 

Guidance and step-by-step instructions for obtaining each of these types of 

PPQ 526 permits can be found at https://www.aphis.usda.gov/aphis/ourfocus/ 

planthealth/import-information/permits/regulated-organism-and-soil-permits 

and https://www.aphis.usda.gov/aphis/ourfocus/planthealth/importinformation/permits/regulated-organism-and-soil-permits/biological-controlorganism-permits. 

PPQ 526 Permit for Importation 

A PPQ 526 Permit for Importation is needed every time live biological control 

organisms are imported into the United States and its Territories. A PPQ 526 

Permit will require an USDA-APHIS inspection containment facility as the 

destination, unless the organisms being imported are species having certain 

exemptions under APHIS regulations 7 CFR 330.200 et seq. 

Additional information concerning containment facilities can be found at 

https://www.aphis.usda.gov/aphis/ourfocus/planthealth/import-information/ 

permits/plant-pests/containment. 

10/2023-05 TAG-BCAW Manual 3-2-3 
Permitting Process for Weed Biological Agents 

PPQ 526 Permit for Interstate Movement 

A PPQ 526 Permit for Interstate Movement is needed every time live weed 

biological control organisms are moved across State lines between any State of 

the United States and its Territories. A PPQ 526 permit is required regardless 

of the use (research, release, etc.). There may be exceptions to the requirement 

for an interstate movement permit for certain biological control organisms. 

PPQ 526 Permit for Continued Curation 

A PPQ 526 Permit for Continued Curation is required in order to retain live 

regulated organisms in containment beyond the expiration of any PPQ 526 

permit that requires containment. When continued movement is involved, 

colonies/cultures of organisms may be kept under a new PPQ 526 Permit for 

importation or interstate movement when renewed. 

PPQ 526 Permit for Removal from Containment 

A PPQ 526 Permit for Removal from Containment is required in order to move 

any live regulated organisms from the confines of an APHIS inspected 

containment for any reason, including movement between containment 

facilities regardless of their relative location (in addition to such movements 

which may be described and permitted in the existing permit). 

If movement between specific containment facilities is already described and 

permitted in an existing PPQ 526 Permit for importation, interstate movement, 

or continued curation, then an additional 526 Permit is not required for such 

movement. 

A PPQ 526 Permit is required to remove a regulated weed biological organism 

from containment and enables release into the environment after the APHIS 

approval, following the processes described in Step 3: APHIS Responses to the 

Recommendation Letter from the TAG-BCAW Chair on page 3-5 and Step 4: 

Environmental Compliance in Support of Petition for Release on page 3-6. 

NOTICE 

Keep in mind that any removal from containment without safeguards (i.e., escapeproof packaging while moving to another containment facility or a physically separate 

part of a containment facility) constitutes release into the environment. 

3-2-4 TAG-BCAW Manual 10/2023-05 
Permitting Process for Weed Biological Agents 

Step 3: APHIS Responses to the Recommendation Letter 

from the TAG-BCAW Chair 

After receiving the TAG-BCAW’s recommendation, APHIS reviews the 

recommendation, including reviewers’ comments and any information cited by 

reviewers, and any additional information available to APHIS in order to 

determine if APHIS will support release of the biological control agent. The 

decision by APHIS to support - or not support - release may or may not agree 

with the TAG-BCAW’s recommendation to release (or not release), based on 

all the information APHIS considers. However, historically the TAG-BCAW’s 

recommendation and the subsequent APHIS decision regarding release 

frequently coincide. 

Soon after receipt of the recommendation letter from the TAG-BCAW Chair, 

APHIS typically writes a letter to inform the Petitioner of the APHIS decision 

regarding support of the request to release the biological control agent, with a 

copy to the TAG-BCAW Executive Secretary. 

In the cases where APHIS supports the request to release, APHIS may still 

request that the petitioner provide additional information or clarification, 

which will be used to support and enhance the environmental compliance 

documents in the following steps. This additional information or clarification 

is usually in response to questions or concerns raised by the reviewers or other 

parties which are often received even with a TAG-BCAW recommendation for 

release. 

When APHIS supports a request for release, the Petitioner may submit an 

application for removal from containment and environmental release of the 

biological control agent. See PPQ 526 Permit for Removal from Containment 

on page 3-4. 

NOTICE 

An application may be submitted by any individual in accordance with APHIS regulations (7 CFR 330.201 through 330.203), and may be from a party who is not the petitioner or researcher, but who is proposing to colonize, increase, or distribute the 

agent. Upon receipt of the application, APHIS will proceed with the environmental 

compliance process described in Step 4: Environmental Compliance in Support of 

Petition for Release on page 3-6. 

When release of the weed biological control agent is not supported by APHIS, 

then APHIS will convey the reasons for not supporting release in the letter to 

the Petitioner, and may outline steps to take if the Petitioner wishes to improve 

the petition. At this point, the decision of the Petitioner or other researchers 

will be whether to invest additional time and resources to improving the 

petition and submitting an amended petition to the TAG-BCAW Executive 

Secretary. The subsequent submission of a new or an amended petition may or 

10/2023-05 TAG-BCAW Manual 3-2-5 
Permitting Process for Weed Biological Agents 

may not lead to a recommendation for release or support for release by APHIS. 

APHIS will deny the application submitted for removal from containment and 

therefore will not proceed with the environmental compliance process 

described in Step 4: Environmental Compliance in Support of Petition for 

Release. 

Step 4: Environmental Compliance in Support of Petition for 

Release 

Issuance of permits by APHIS for the environmental release of nonindigenous 

weed biological control organisms is considered a Federal action and triggers 

compliance with the Endangered Species Act (ESA) and the National 

Environmental Policy Act (NEPA). Steps and procedures APHIS follows to 

comply with these Acts regarding the proposed release of biological control 

agent against weeds are described in Compliance with the Endangered Species 

Act (ESA) and Compliance with the National Environmental Policy Act 

(NEPA). 

The petitioner should apply for a PPQ 526 Permit to remove a weed biological 

control organism from containment (see PPQ 526 Permit for Removal from 

Containment on page 3-4) after receipt of a letter from APHIS indicating 

support of the request to release the weed biological control organisms into the 

environment of the United States. APHIS proceeds with the steps for 

environmental compliance with these environmental Acts in response to 

receipt of the application for the permit to release (removal from containment). 

Compliance with the Endangered Species Act (ESA) 

According to the ESA, any action that is authorized, funded, or carried out by a 

Federal Agency must comply with the consultation requirements of Section 7 

of the ESA. (See Section 7 Consultations on page 6-1 and ESA Compliance on 

page 6-1.) Although the researcher should have received input from the 

USFWS or possibly the National Marine Fisheries Service from the beginning, 

APHIS-PPQ determines if consultation with the USFWS or possibly the 

National Marine Fisheries Service must be conducted at this point in the 

process. If the proposed release will have no effect on listed species or 

designated critical habitat, then no consultation with the USFWS or the 

National Marine Fisheries Service is required. 

Informal consultation with the USFWS or possibly the National Marine 

Fisheries Service occurs when the release of the biological control organism 

“may affect, but is not likely to adversely affect” listed species or designated 

critical habitat. 

3-2-6 TAG-BCAW Manual 10/2023-05 
Permitting Process for Weed Biological Agents 

The document required for Section 7 consultation with the Services is a 

biological assessment (BA). This document is prepared by APHIS and is 

submitted to the USFWS or possibly the National Marine Fisheries Service. 

The BA includes several elements: 

1. A description of the action to be considered. 

2. A description of the specific area that may be affected by the action. 

3. A description of any listed species or critical habitat affected by the action. 

4. A description of the manner in which the action may affect any listed 

species or critical habitat and an analysis of any cumulative effects. 

5. Relevant reports, including any EA or EIS. 

6. Other relevant information on the action, affected listed species, or critical 

habitat. 

The USFWS reviews the BA, and if they concur with the “may affect, not 

likely to adversely affect” determination, then USFWS will send APHIS a 

concurrence letter and the consultation process is complete. Once complete, 

APHIS incorporates the concurrence from USFWS into the environmental 

assessment (EA), and makes any final changes necessary. 

In very rare cases, APHIS may pursue formal consultation with the USFWS. 

Formal consultation is required when APHIS determines that the proposed 

release “may affect and is likely to adversely affect” listed species or 

designated critical habitat. Typically, APHIS does not proceed with formal 

consultation except under the unusual circumstances, where the adverse effect 

may be in doubt, or is likely to be very limited. 

Compliance with the National Environmental Policy Act (NEPA) 

The document required for National Environmental Policy Act (NEPA) 

compliance is the environmental assessment (EA), a concise public document 

that provides evidence and analysis to determine whether a Finding of No 

Significant Impact (FONSI) can be reached. The EA is prepared by APHIS 

staff scientists. The EA provides the public with the potential positive and 

negative environmental impacts, both direct and indirect, that may occur 

following release into the environment. Petitioners from other Federal agencies 

must also consider their own NEPA implementing procedures specific to any 

proposed actions. 

10/2023-05 TAG-BCAW Manual 3-2-7 
Permitting Process for Weed Biological Agents 

Once the EA has been completed, APHIS-PPQ publishes a 30-day notice of 

availability of the EA in the Federal Register to allow public comment on the 

proposed action. After considering the comments, APHIS does one of the 

following: 

Reaches a finding of no significant impact (FONSI); or 

Is unable to reach a FONSI and concludes that preparation of an 

environmental impact statement (EIS) is required. An EIS is a document 

prepared in compliance with NEPA when significant impacts are 

expected from the proposed action 

If a FONSI has been reached, APHIS will publish the availability of the 

FONSI in the Federal Register and post the final EA and FONSI on the APHIS 

Plant Health Environmental Assessments Web site https:// 

www.aphis.usda.gov/aphis/ourfocus/planthealth/plant-pest-and-diseaseprograms/ea/ct_plant_health_environmental_assessments. 

Step 5: Compliance With Executive Order 13175 

APHIS, like other Federal Agencies, is bound to comply with various 

Executive Orders (EO), some of which apply to these proposed actions. EO 

13175, Consultation and Coordination with Indian Tribal Governments, was 

issued to ensure that there would be meaningful consultation and collaboration 

with tribal officials in the development of Federal policies that have tribal 

implications. Therefore, APHIS implements contact and communication with 

Federally-recognized tribal governments regarding the proposed 

environmental release of weed biological control organisms. 

Typically, prior to the publication of the EA in the Federal Register, APHIS 

staff prepares a letter describing the proposed Federal action and requests 

review and input from Native American Tribes in any area likely to be 

inhabited or affected by the release of the proposed biological control agent 

against weeds. If the tribal government requests consultation with APHIS, 

environmental compliance and other actions in preparation of the proposed 

release are paused until consultation is concluded. 

3-2-8 TAG-BCAW Manual 10/2023-05 
Chapter 

4 Biological Control of 

Weeds 

Introduction 

Contents 

Introduction 4-1-1 

Biological Control 4-1-1 

Risk Analysis of Biological Control Agents of Weeds 4-1-3 

Introduction 

The Introduction section of the Biological Control of Weeds chapter provides a 

brief introduction to biological control. 

Biological Control 

Classical biological control of weeds is a weed control method where exotic 

natural enemies are used to reduce exotic weed infestations. The practice of 

weed biological control in the United States began in the 1940s and has 

resulted in some spectacular successes in the suppression of the targeted weed. 

One of the earliest and best known examples is the introduction of Chyrsolina 

leaf beetles for control of Klamath weed, a poisonous weed that invaded dairy 

pastures and rangelands in the western United States and Canada. Classical 

weed biological control of weeds has also resulted in a number of situations 

where the exotic control agent becomes established, but fails to suppress the 

target weed. 

Several different kinds of organisms have been used as biological control 

agents of weeds: insects, mites, nematodes, and plant pathogens; of these, 

herbivorous insects are the most common weed biological control agent. 

Efforts to develop a weed biological control agent consist of the following 

steps: 

1. Foreign exploration in the weed’s area of origin. 

2. Host specificity studies. 

3. Approval of the exotic agent by government regulatory authorities. 

4. Release and establishment in areas invaded by the target weed. 

5. Post-release monitoring. 

10/2023-05 TAG-BCAW Manual 4-1-1 
Biological Control of Weeds 

Biological Control 

Biological control is one of the many weed management options used alone or 

combined with other management approaches. The use of biological control 

agents of weeds may be the preferred or only tool available in some habitats or 

situations, although chemical, cultural, and mechanical options have their 

place, too. Many land managers, ranchers, and farmers use an integrated weed 

management approach, combining more than one method to control weeds. 

TAG-BCAW’s mission statement is, “To facilitate proposed biological control 

agents of weeds in North America by providing guidance to researchers and 

recommendations to regulating Agencies for or against release of 

nonindigenous biological control agents of weeds. This is based on 

considerations of potential nontarget impacts, conflicts of interest, natural 

resources, agricultural production, and the Endangered Species Act (ESA) 

Threatened and Endangered Species List.” The TAG-BCAW’s role in the 

development of a classical weed biological control agent is to review the 

information obtained during the host specificity studies and provide a 

recommendation to the USDA-APHIS-PPQ as to the proposed biological 

control agent of weeds and its potential for non-target impacts. 

The ecological implications of managing exotic species with exotic biocontrol 

agents intentionally introduced from the native range of the target weeds must 

be thoroughly evaluated before release. Potential risks are systematically 

evaluated using established, standardized protocols that yield repeatable, 

scientifically valid and conclusive data. 

Historically, biological control has been most effective against large 

infestations of a single weed species, and has been most successful on weeds 

that have been introduced into areas where co-evolved natural enemies do not 

occur. 

Biological control has several advantages over other types of weed control 

(Wapshere, et al., 1989). These advantages include long-term or sustained 

management of the target plant, limited treatment side-effects or nontarget 

effects, attack restricted to one or a few very-closely related weed species, selfperpetuating agents, and nonrecurring costs. 

TAG-BCAW plays a role in evaluating the introduction an exotic organism to 

control weed infestations by objectively weighing such advantages against 

potential non-target impacts and conflicts of interest. 

Wapshere et.al.’s (1989) article “Recent Developments in Biological Control 

of Weeds” (see References on page 4-3), provides a review, examples, and a 

discussion of the advantages and disadvantages of different approaches to 

biological control of weeds, such as classical, augmentative, inundative, or 

conservation approaches. 

4-1-2 TAG-BCAW Manual 10/2023-05 
Biological Control of Weeds 

Risk Analysis of Biological Control Agents of Weeds 

Risk Analysis of Biological Control Agents of Weeds 

The aim of host specificity and other pre-release studies of a proposed 

biological control agent are to produce a body of information for regulatory 

authorities to perform an ecological risk analysis of the potential for direct 

damage to economic and native non-target plant species following release of 

the control agent. Risk analysis consists of three elements: hazard 

identification, analysis of exposure, and analysis of probability. Hazard 

identification is achieved through the host specificity testing where the 

different life stages of the proposed biological control agent that pose the threat 

are identified and the agent’s fundamental host range is described. Analyses of 

exposure and probability are based on the predicted field host range following 

release and the predicted actual damage to non-target species. 

The fundamental host range of a species is the absolute limit of its host range 

and is genetically determined. The field host range is the subset of hosts used 

by a species following its release into the environment and will vary with 

availability of hosts (e.g., geographic allopatry, host synchrony), genetic 

variation in host vulnerability (e.g., defense chemicals), and the behavior and 

physiology of the control agent. The fundamental host range can be defined 

using no-choice or starvation tests in which a proposed biological control agent 

is exposed to a non-target plant which must be utilized or the agent dies. 

Information on the field host range is predicted from results obtained during 

choice tests in the laboratory and in the field. Based on the results of all tests 

and other behavioral and life history observations, predictions are made on the 

likelihood that a potential agent will damage a particular plant or group of 

plants in the environment it is to be released. 

References 

For more information about biological control of weeds, refer to the following 

listed references as well as those listed in Biological Control of Weeds on page 

F-10. 

Charudattan, R.; Walker, H.L., eds. 1982. Biological Control of Weeds with Plant 

Pathogens. New York, NY: John Wiley & Sons, Inc. 

Hoddle, M.S. 2004. Restoring balance: Using exotic species to control invasive exotic 

species. Conservation Biology 18: 38-49. 

McFadyen, R.E. 1998. Biological Control of Weeds. Annual Review of Entomology 43: 

369-393. 

TeBeest, D.O., ed. 1991. Microbial Control of Weeds. New York, NY: Chapman and 

Hall. 

Van Dreische, R.; Hottle, M; Center, T. 2008. Control of Pests and Weeds by Natural 

Enemies: An Introduction to Biological Control. Blackwell Publishing Ltd. 

Wapshere, A.J.; Delfosse, E.S.; Cullen, J.M. 989. Recent developments in biological 

control of weeds. Crop Protection 8: 227–250. 

10/2023-05 TAG-BCAW Manual 4-1-3 
Biological Control of Weeds 

Risk Analysis of Biological Control Agents of Weeds 

4-1-4 TAG-BCAW Manual 10/2023-05 
Chapter 

4 Biological Control of 

Weeds 

Identification and Characterization of Agents 

Contents 

Introduction 4-2-1 

Identification and Characterization of Proposed Biological Control Agents of 

Weeds 4-2-1 

Approaches, Methods, and Tools for Identification and Characterization of the 

Agent 4-2-4 

Taxonomic Approaches 4-2-4 

Morphological Methods 4-2-4 

Functional Analysis 4-2-5 

Molecular or Genetic Tools 4-2-5 

Cryptic or Sibling Species 4-2-7 

Challenges 4-2-7 

Experts 4-2-8 

Reference Collections 4-2-8 

Introduction 

The Identification and Characterization of Agents section of the Biological 

Control of Weeds chapter provides information that is intended for and is 

pertinent to all classes of agents, including arthropods, plant pathogens, and 

nematodes. 

Identification and Characterization of Proposed Biological Control 

Agents of Weeds 

Successful classical biological control of weeds requires accurate identification 

and characterization (biological, chemical, ecological, and phylogenetic) of the 

proposed biological control agent of weeds. 

Target and agent identification and characterization are critical because they 

have the potential to do the following: 

Affect future evaluation processes 

Influence future assessments of risk 

Provide a gateway to knowledge through published literature and reports 

10/2023-05 TAG-BCAW Manual 4-2-1 
Identification and Characterization of Proposed Biological Control Agents of Weeds 

Preclude introduction of unapproved organisms 

Both petitioners and the TAG-BCAW reviewers should consider the following 

questions when describing an agent: 

What is the agent? (e.g., insect, mite, fungus, bacterium, virus, nematode) 

What is the life cycle of the agent? 

What other information (e.g., biological, chemical, ecological) should be 

known about the agent? 

Why is this information needed? 

What type of information about the identification and characterization of 

the agent needs to be documented in the petition? 

How can pertinent information be best conveyed to others? 

There are many complex questions associated with the identification and 

characterization of proposed biological control agents of weeds, target weeds, 

and close relatives of both. Addressing these requires highly-specialized 

technical expertise. TAG-BCAW members who are unfamiliar with certain 

subject areas are encouraged to consult with experts for additional help in 

verifying information presented in petitions. 

Some of the complex questions associated with the identity and 

characterization of an agent are as follows: 

What is the scientific name of the agent (at minimum, genus and species)? 

Who determined the name (i.e., taxonomic authority)? What is the level 

of confidence of this determination? 

How is the agent related to other taxonomic groups? 

Are the voucher specimens deposited in a national museum where they 

are accessible to scholars and international experts? 

Does the agent (or a closely-related species) already occur in areas likely 

to be the targeted for agent release? 

Can the agent be differentiated below the species level and if so is it 

currently resolved and uncontested? 

Can the agent’s presence post-release be unambiguously confirmed (e.g., 

based on sampling evidence that the natural enemy is present, and feeding 

damage to host plants)? 

4-2-2 TAG-BCAW Manual 10/2023-05 
Identification and Characterization of Proposed Biological Control Agents of Weeds 

How does the agent affect the target weed (e.g., defoliation, stem or root 

galling, seed destruction, etc.), and is damage caused by a specific life 

stage of the agent? 

Are the agent’s intensity and scale (individual, patch, or population level) 

of damage on the target weed well characterized? 

10/2023-05 TAG-BCAW Manual 4-2-3 
Approaches, Methods, and Tools for Identification and Characterization of the Agent 

Approaches, Methods, and Tools for Identification and 

Characterization of the Agent 

Researchers use a variety of approaches, methods, and tools to identify and 

characterize biological control agents of weeds. A critical challenge for the 

TAG-BCAW is determining if the approaches, methods, and tools employed 

confer an appropriate level of confidence in identifications and 

characterizations.What is the evidence? How is the evidence presented? 

Taxonomic Approaches 

For proposed biological control agents of weeds, taxonomic identification 

must be provided at minimum to the species level. In some cases, 

identification below the species level may be necessary. For many microbial 

groups, sexual and asexual forms exist for a given species. Taxonomy may be 

based on spore forms or other reproductive characteristics. For other groups, 

biotypes, genotypes, strains, pathotypes, and subspecies exist. These sub-taxa 

are characterized in different ways; for example, some may refer to isolates. 

Isolates are often limited collections made from a specific location, and may 

not represent the entire genetic diversity of the species. Accuracy in naming 

potential biological control agents of weeds is as important as accurate 

characterization (biological, chemical, ecological). 

Morphological Methods 

Conventional morphological methods are often initially used to determine 

species identity. Physical attributes unique to the species are used to generate a 

diagnosis that can be used to distinguish the agent from close relatives once it 

has been released. 

Attributes may include: 

Armature (spine, hairs) 

Body shape and size 

Color patterns 

Cuticle surface 

Internal Structures (stylet, reproductive organs, etc.) 

Morphometric parameters 

Physiological (spiracles, pores) structures 

Reproductive structures 

Shape and number of appendage (antennae, legs, palpi, etc.) segments 

4-2-4 TAG-BCAW Manual 10/2023-05 
Approaches, Methods, and Tools for Identification and Characterization of the Agent 

Functional Analysis 

Functional analysis of characteristics, such as part of the host plant utilized, 

feeding behavior, or infection parameters can also be incorporated into the 

identification of an agent. In some cases, these methods can provide a more 

accurate way to identify an agent. 

EXAMPLE For example, plant galling arthropods are typically identified from the location (on host plant) and unique morphology of the galls; this approach provides a more certain yet simple identification of the arthropod species than 

the morphological traits of the arthropod species itself. 

Other methods for characterizing an agent involve biological or chemical 

characterization using a range of available tools. 

In some cases, assessments of agent identity must extend beyond taxonomy to 

include the following biological and chemical characterizations: 

Biological traits such as growth on selective media (microbes), phenology, 

diapause; 

Enzymatic reactions and other chemical analyses; 

Host indexing for characterizing pathogens; 

Disease symptoms/damage patterns; 

Hybridization studies and evaluation of reproductive strategies employed 

by an agent; and 

Range location and relationship to other ecotypes. 

Molecular or Genetic Tools 

Identification and characterization of an agent using molecular or genetic tools 

yields more definitive agent identification and can significantly enhance or 

reveal complex agent characterizations. 

A number of techniques have been used to identify biological control agents: 

Allozymes and proteins: compare data between geographical isolates; 

Amplified fragment length polymorphism (AFLP) and Selective 

Amplification of Microsatellite Polymorphic Loci (SAMPL): assess 

variation among individuals of the same species; 

DNA bar-coding; 

DNA sequencing: differentiate species and populations; 

Multiple Arbitrary Amplicon Profiling (MAAP): assess variation among 

individuals of the same species; includes RAPD, ISSRs, UP_PCR, DAF 

techniques; 

10/2023-05 TAG-BCAW Manual 4-2-5 
Approaches, Methods, and Tools for Identification and Characterization of the Agent 

Microsatellites or Simple Sequence Repeats (SSRs): differentiate species 

and populations; 

Polymerase chain reaction (PCR): qualitative and quantitative (qPCR) 

detection of species; and 

Restriction fragment length polymorphism (RFLP): differentiate between 

closely-related taxa. 

Sequencing of diagnostic rDNA regions is now preferred as fast and accurate 

and decreasing costs. DNA bar-coding uses molecular markers such as COI, 

CO IIITS, 12S rRNA, 16S rRNA, 18S rRNA, 28S rRNA, and heat shock 

protein 90 (hsp90), and will distinguish most species, including cryptic 

species, immature stages, and unknown species. Sequencing technology is 

rapidly developing. Second generation techniques such as pyrosequencing, 

sequencing by synthesis and sequencing by ligation are vast improvements on 

first generation or Sanger sequencing. Third generation techniques are already 

under development. Molecular data provides the capacity to label agents for 

later verification. 

4-2-6 TAG-BCAW Manual 10/2023-05 
Challenges 

Challenges 

The TAG-BCAW is continually challenged to accurately assess the petitioners’ 

identification and characterization of proposed biological control agents of 

weeds. 

Species identifications or characterizations presented in petitions or test lists 

may be incorrect. When this occurs, implications are as follows: 

Hampering of access to published information may be due to incomplete 

names; 

Loss of effort thus far invested toward biologically controlling weeds; 

Misguided sense of confidence using a knowledge base that is 

inappropriate to the proposed biological control agent of weeds being 

studied; and 

Potential to improperly assess the risk factors. 

Cryptic or Sibling Species 

The presence of cryptic or sibling species in shipments of proposed agents 

received in containment facilities may go unnoticed, depending upon 

taxonomic status of the group involved. Cryptic or sibling species can cause 

serious problems in host plant testing, resulting in inaccurate or erroneous 

assessments of host range and in quarantine operations after the research has 

been completed and the agent has been approved for release. 

In this situation, the wrong or untested species may be included in 

environmental releases. 

EXAMPLE Populations collected from a geographically distant part of a tested 

agent’s range may prove to be a different species, even though the 

populations appear to be similar. 

The unintentional release of cryptic or sibling species has been documented in 

existing North American weed biological control programs. Researchers and 

TAG-BCAW reviewers alike can prevent this problem by questioning whether 

such possibilities might exist in the reported identification process. 

10/2023-05 TAG-BCAW Manual 4-2-7 
 

 

Challenges 

Experts 

What is an expert? Does the expert have the appropriate breadth of 

knowledge? Who are the world authorities? What is the expertise of the person 

who is describing the characterization? Not all experts agree, so there may be 

some confusion relying on them. Since world authorities are not always 

accessible and may lack critical knowledge of certain groups, definitive 

identification is not always possible. It is therefore extremely important that 

individuals of the species approved for release always come from the same 

population tested with a reference collection made of individuals from the 

population released (see below). 

Reference Collections 

Reference collections support biological control and hold specimens of 

proposed biological control agents that have been studied by taxonomists. In 

some cases, access to reference collections is limited, since collections may be 

located in foreign museums. Reference collections and hands-on experience 

may be limited to geographic regions. If these geographic regions fall outside 

of the main region being studied by taxonomic experts, then the experts may 

have limited capacity to identify exotic agents. 

EXAMPLE Agents from the southern hemisphere and from locations in the Old World 

may not be represented in U.S. reference collections; therefore, definitive 

identification may not be possible by U.S. taxonomists. 

As required by NAPPO RSPM No. 7, a reference collection of 10 or more 

individuals from the released population must be deposited in a national 

collection. It is recommended that the specimens be deposited in national 

collections of Canada, Mexico, and the United States to ensure that the experts 

in North America conducting future taxonomic studies have access to, and 

include representatives of the biological control agent. Specimens should be of 

good condition for DNA extraction and with clear labels indicating collection 

locality, latitude and longitude, date of collection, name of collector, and any 

other pertinent information. A letter explaining that the specimens are 

biological control agents and are being donated to the National Collection as 

part of the conditions under which release will be granted should accompany 

the specimens when they are submitted. A copy of the letter should be included 

in the petition submission to TAG-BCAW. 

See Table 4-2-1 for National Collections for Specimens. 

4-2-8 TAG-BCAW Manual 10/2023-05 
 

Challenges 

Table 4-2-1 National Collections for Specimens 

Country Designated Collection Manager Contact Information 

United States of America Dr. Floyd Shockley, Acting Collections Manager 

Canada 

Mexico 

National Museum of Natural History 

Smithsonian Institution 

PO Box 37012, MRC 165, Room CE-419 

Washington, DC 20013-7012 

United States of America 

Dr. Owen Lonsdale, Collections Manager 

Canadian National Collection of Insects, Arachnids 

and Nematodes 

Agriculture and Agri-Food Canada/Agriculture et 

Agroalimentaire Canada 

KW Neatby Building 

960 Carling Avenue 

Ottawa, ON K1A 0C6 

Canada 

Christina Mayorga Martinez 

Instituto de Biologia - UNAM 

Departamento de Zoologia 

3er Circuito Exterior s/n 

Ciudad Universitaria 

Alcaldía Coyoacán 04510 

Ciudad de México 

México 

Phone: 202-633-0990 

Fax: 202-786-2894 

shockleyf@si.edu 

Phone: 613-759-1992 

Fax: 613-759-1927 

owen.lonsdale@agr.gc.ca 

Phone: 55 22 57 17 99 

mayorgac@ib.unam.mx 

Taxonomic Authority 

The petitioner must include the name of the recognized taxonomic authority in 

that particular taxon. If the name of the agent species is not listed, then the 

petitioner must include a letter from the expert taxonomist in the particular 

taxon so stating. Taxonomists may be reluctant to go on record with 

determinations unless they have a high level of confidence in their assessment. 

The use of incomplete names is not necessarily a limitation, since much of the 

assessment is based on biological information obtained after collection. 

Has the taxonomic authority done historical research on the taxonomy of the 

relevant taxon? Minor frustrations may occur in assessing the knowledge base 

because of synonymies (process), revisions to new genera, and other changes 

in the names by which information on agents is retrieved. 

References 

For more information about identification and characterization of agents, see 

References on page F-1. 

Abebe, E.; Mekete, T.; Thomas, W.K. 2011. A critique of current methods in nematode taxonomy. African Journal of Biotechnology 10: 312-323. 

10/2023-05 TAG-BCAW Manual 4-2-9 
Challenges 

Gaskin, J.F.; Bon, M-C.; Cock, M.J.W.; Cristofaro, M.; De Biase, A.; De Clerck-Floate, R.; Ellison, C.A.; Hinz, H.L.; Hufbauer, R.A.; Julien, M.H.; Sforza, R. 2011. Applying molecular-based 

approaches to classical biological control of weeds. Biological Control 58:1-21. 

NAPPO (North American Plant Protection Organization). 2015. Guidelines for Petition for First 

Release of Non-indigenous Phytophagous or Phytopathogenic Biological Control Agents. 

Regional Standard for Phytosanitary Measures (RSPM) No. 7. Available at: https:// 

www.nappo.org/application/files/5315/8352/2957/RSPM_07-30-07-15-e.pdf 

4-2-10 TAG-BCAW Manual 10/2023-05 
Chapter 

4 Biological Control of 

Weeds 

Host Specificity Testing of Arthropods 

Contents 

Introduction 4-3-1 

Host Plant Selection 4-3-2 

Host Specificity Testing 4-3-2 

Rigidity of Arthropod Behavior: Importance to Host Specificity Testing 

4-3-3 

Screening Tests 4-3-4 

No-choice Plant Tests 4-3-5 

Multiple-choice Plant Tests 4-3-6 

Oviposition Testing 4-3-6 

Field Testing 4-3-7 

Experimental Design 4-3-8 

Introduction 

The Host Specificity Testing of Arthropods section of the Biological Control of 

Weeds chapter provides the guidelines for host specificity testing of all 

arthropod species that are potential classical biological control agents of 

weeds. These guidelines must be read and comprehensively understood by all 

TAG-BCAW members that review and evaluate petitions submitted for 

environmental releases of new proposed biological control agents of weeds 

(i.e., species not previously screened and then approved for environmental 

release). 

The sequence of tests described here is an example, and is not intended to 

serve as a definitive checklist. Details of any host specificity tests vary 

according to the biology and life history of each proposed species. When 

reviewing the methods section of a petition, evaluate if the petitioner has used 

an appropriate method for studying the host range of the species. 

10/2023-05 TAG-BCAW Manual 4-3-1 
Host Plant Selection 

Host Plant Selection 

A strategy based on the Wapshere centrifugal method for selecting plants for 

host specificity testing is covered under Test Plant Lists on page 5-1. Briese 

proposed a more advanced approach that uses plant molecular systematics in 

test plant species choice. Alternative host plant selection strategies may also be 

used. 

The identity of the plants must be confirmed, the person identifying the plants 

must be named, and the source of propagative material must be clearly stated. 

The centrifugal testing approach may not be appropriate for all organisms, 

particularly facultative saprophytes (i.e., culturable organisms), thus criteria 

for selecting test plant species should be clearly stated. 

Host Specificity Testing 

Host specificity testing is the process of rigorously evaluating a proposed 

species to determine its field host range. The field host range consists of those 

plants on which all individuals of the species would consistently develop 

normally and complete their life cycle in nature. Host specificity testing of 

proposed arthropod agents begins with field studies of the species when 

initially discovered in the native range on the target weed. 

Once a potential agent has been found feeding on the target weed in the field, 

the first step is usually to survey the surrounding plants, particularly those in 

the same family as the target weed. This type of survey can give the researcher 

a preliminary indication of whether the arthropod is a generalist or specialist 

herbivore. Similarly, once the species is identified, a literature search will often 

indicate if the arthropod is likely to have too broad a host range to be 

considered as a proposed biological control agent of weeds. Species confirmed 

to be generalist feeders or those with a broad host range are dropped from 

further consideration. Researchers then focus their efforts on evaluating more 

promising potential agents under controlled environmental conditions. This 

evaluation determines if the proposed species’ host range is limited enough to 

make it a feasible biological control agent. 

No set protocol or standard procedure is routinely used for host specificity 

testing. Different tests must be developed and implemented for each proposed 

species, depending upon feeding behavior or the part of the plant on which it 

feeds. 

The individuals used in host specificity testing may be from wild populations 

collected in the field or from laboratory-reared colonies. Both sources have 

4-3-2 TAG-BCAW Manual 10/2023-05 
Host Specificity Testing 

advantages and disadvantages which can ultimately affect the results of host 

specificity testing. 

For some species, field-collected material is frequently more readily attainable 

and cheaper to use than trying to establish and maintain a laboratory colony. 

A disadvantage of using field-collected individuals is that they may be 

contaminated with diseases or parasitoids which could ultimately affect their 

behavior. Furthermore, a researcher is less able to control for age and vigor of 

field-collected material (e.g., females may already have laid most of their eggs 

at the time of collection). 

Laboratory-reared individuals are easier to control and provide a better 

opportunity for researchers to observe the arthropod’s biology and life history 

attributes more closely. In addition, laboratory colonies, compared to wild 

populations, provide a more genetically homogeneous population to work with 

that is free of diseases and parasites. Unfortunately, laboratory colonies can 

undergo genetic bottlenecks resulting in behavioral changes or loss of vigor, 

particularly if the individuals are continuously reared on artificial diets or the 

colonies are continuously reared through numerous generations. This can be 

mitigated by periodically introducing field-collected individuals sourced from 

the original collecting location to laboratory colonies, or by maintaining 

separate genetic lines of the agent which are periodically crossed to sustain 

genetic diversity and colony vigor. 

Natural populations of a proposed species may be quite small or available only 

for very limited periods of time, while laboratory-reared colonies can provide a 

large and constant year-round supply of experimental subjects. 

In general, proposed species selected for screening or starting a rearing colony 

should originate from a single and clearly-defined collection site. This ensures 

that the population of an agent that is to be released retains the same genetic 

diversity and characteristics as the population that was tested. 

Rigidity of Arthropod Behavior: Importance to Host 

Specificity Testing 

As arthropods select host plants and feed on them, they appear to transition 

smoothly from one behavior to another—walking, stopping, and feeding just 

as mammals do. Nonetheless, arthropod behavior is generally much less fluid 

than that of mammals. Insects and mites find, preliminarily assess, then select 

and feed on hosts in a series of discrete steps, each step mediated by a 

particular physical or chemical stimulus. In some cases, serio-chemical cues 

must be present for the arthropod to sustain its feeding behavior. If critical 

stimulus is lacking, then host selection or feeding may be aborted triggering a 

different behavior, such as flying away to search for another plant. 

10/2023-05 TAG-BCAW Manual 4-3-3 
Host Specificity Testing 

Not all arthropods have the same sequence of behaviors. Certain steps 

displayed by one species may not be displayed by another. Nevertheless, 

arthropod behavior is generally considered to be rigid, at least at the gender 

and life stage within the species level, and this rigidity constitutes an important 

basis for scientists’ confidence in the results of host specificity tests. Under 

both natural (unmanipulated) field and controlled experimental test conditions, 

genetically-determined behaviors prevent arthropods from skipping over steps 

in order to satisfy their need for food. 

Immature arthropods usually have host plants selected for them by ovipositing 

adults. Immature arthropods may therefore have relatively under-developed 

host discrimination abilities. When arthropods deposit eggs on unsuitable host 

plants, larvae may or may not still attempt to feed. If the host plant is of poor 

nutritional quality or possesses defensive chemicals, then larvae either may 

either grow and develop for a time but fail to complete development, or they 

may complete development but emerge as undersized adults. The production 

of undersized adults can be indicative of additional deleterious physiological 

effects; affected adults may also be sterile or less fecund. For some species, 

such as many root feeders, larvae are able to seek out suitable hosts, so host 

selection for oviposition is likely more random. 

Screening Tests 

Current practices involve a tiered approach to non-target testing. The general 

sequence is no-choice tests on as many test plant list species as possible, 

followed by multiple choice tests (agent simultaneously exposed to one or 

more non-target species and the target weed). Tests use standardized 

observations of feeding or oviposition and measures of development to 

compare acceptance and suitability of target and non-target plant species. 

Researchers should strive to conduct tests on the biologically and ecologically 

relevant phenological stages of test plants. Final testing of the most promising 

proposed biological agents of weeds is frequently conducted in field cages or 

as open field tests in the agents’ and target weeds’ country of origin. 

4-3-4 TAG-BCAW Manual 10/2023-05 
No-choice Plant Tests 

No-choice Plant Tests 

During the initial stage of evaluation, all species identified on the test plant list 

(see Test Plant Lists on page 5-1) are considered to be potentially at risk of 

attack by the proposed biological control agent of weeds, according to their 

degree of relatedness to the target weed. The first level of host specificity 

testing usually concentrates on quick, simple tests to evaluate the response of 

the proposed organism to the selected plant species. Such preliminary testing is 

referred to by several different names—first-phase host testing, no-choice 

testing, starvation testing, or single-plant testing—but usually follows the same 

general procedure. Published strategies for preliminary testing are further 

discussed in Testing Methodology for Biological Control on page F-25. 

In general, preliminary testing involves placing immatures of the potential 

agent on the appropriate plant part/phenological stage of the non-target 

species, either in a container (such as a petri dish) or enclosed on potted plants 

where they either feed or eventually die because the host is fundamentally 

unacceptable. Observations of a similar number of immatures of the potential 

agents placed on the same part of the target weed serves as a positive control. 

At the coarsest resolution of host acceptance behavior, arthropods probe test 

plants with mouth parts or ovipositors in an effort to discriminate between 

hosts and non-hosts. In general, such minor probing or tasting are not 

considered to be true feeding, and for all practical purposes can be regarded as 

nonfeeding. 

Arthropods may ingest enough material on certain plants to produce droppings. 

However, if the life span of the organism will be extended but there is little 

evidence of continued development, then these accepted but unsuitable species 

can also be discarded as potential host plants. A final category of host-plant 

interaction is characterized by those plant species on which the proposed 

biological control agent of weeds readily feeds, grows, and appears to undergo 

successful development. As potentially accepted and suitable non-target hosts, 

risks to these plant species must be further evaluated using more refined 

assessments. 

10/2023-05 TAG-BCAW Manual 4-3-5 
Multiple-choice Plant Tests 

Multiple-choice Plant Tests 

The next level of host specificity testing aims to approximate more natural 

conditions where arthropods can freely select both the plant species and part of 

the plant on which to feed, complete development, or oviposit. These tests 

typically require a reliable supply of live, healthy, potted plants. Plant parts (at 

minimum, large healthy bouquets of foliage, flowers, seeds, fruit, roots, or 

stems) can be acceptably used under certain circumstances. Arthropod 

behavior is often influenced differently by constituent cues produced by intact 

test plants, in comparison to elicited cues produced as part of test plant damage 

or wounding responses. Researchers and TAG-BCAW reviewers alike must 

carefully consider the implications of using plant parts rather than whole plants 

on test results reported in petitions. 

Like the no-choice tests, multiple-choice tests may indicate that although 

development can be successfully completed on non-target species, it may take 

significantly longer than for the individuals feeding on the target weed (used as 

a positive control). Arthropods completing development on non-target species 

may emerge as smaller and less reproductively fit adults than those produced 

on the target host. 

The main purpose of these secondary feeding tests is to identify and eliminate 

from further testing non-target plant species that are not at risk, and focus 

additional testing on those species that appear to support normal arthropod 

development. 

Oviposition Testing 

Arthropods may complete normal development when confined on nontarget 

species. This does not necessarily mean that nontarget plants would be 

selected as hosts under (unmanipulated) field conditions. Furthermore, plants 

must first be recognized as hosts before they can be selected by ovipositing 

females. Oviposition preference is therefore given strong consideration in host 

specificity testing. Oviposition testing requires larger cages in which mated 

females can freely move around and choose between non-target and test weed 

test plants. If oviposition is observed, then the plants are retained under typical 

field growing conditions to see if eggs will hatch and the larvae will complete 

their development and produce normal adults. 

Like most tests under conducted laboratory conditions, oviposition tests are 

subject to many limitations. The confined space in the cage or mixing of odors 

from the enclosed plants can confuse the female into laying eggs on what 

otherwise would bean unsuitable host. If the foliage of the test plant and the 

positive control are intertwined, then the female can accidentally deposit eggs 

on the wrong plant. Some arthropod species use serio chemical or tactile cues 

to determine if conspecific eggs have already been laid on a plant; if the 

4-3-6 TAG-BCAW Manual 10/2023-05 
Field Testing 

number of eggs present exceeds an acceptable threshold, then the female will 

automatically move on to search for an oviposition site with fewer or no eggs. 

Because the life span of many arthropod species is relatively short, most 

females deposit all of their eggs in a fairly restricted oviposition period. If the 

females do not find a suitable host in time, then they may resort to depositing 

their eggs on any available surface, on what would under normal conditions be 

considered an unsuitable host. Thus the placement of an egg on a non-target 

plant may not be the result of intentional selection by the female. The 

importance of using plant material at the appropriate stage of development 

(phenology) and in a healthy condition for exposure to the proposed biological 

control agents of weeds is a critical consideration. Results of ovipositing tests 

must be analyzed carefully with a sound understanding and consideration of 

the biology and ecology of the potential agent. 

Oviposition tests are another way to eliminate additional plant species from 

further testing. These tests can provide useful information on the host 

specificity of an arthropod species, but they may not provide definitive 

answers to the question of ecological host range. 

Field Testing 

The most generally-accepted, accurate information on the field host range of a 

proposed arthropod biological control agent is obtained from tests conducted 

under natural field conditions. Ideally, nontarget plant species are cultivated 

alone or in intermixed plots with the target weed in areas where a natural 

population of the proposed arthropod is known to be present. Arthropods from 

the surrounding population freely select among the test plants and the target 

weed for oviposition and subsequent larval development. While this is a much 

more definitive test, this also has its disadvantages. 

Often the foreign country where the field tests are to be conducted will not 

allow North American plants to be introduced and planted due to the risk that 

they may escape and become weeds. After planting the test plants, the 

arthropod population in the area may be too low to allow for a realistic 

assessment. Sometimes this situation can be overcome by enclosing the plants 

in large cages, collecting the arthropods from the surrounding area (or rearing 

them artificially in a laboratory), and releasing relatively large numbers in the 

cage. This remedy may, however, reproduce the cage test biases described 

above. 

Field testing may also include no-choice methods (e.g., releasing on critical 

non-target species patches without the weed present). 

10/2023-05 TAG-BCAW Manual 4-3-7 
Experimental Design 

Experimental Design 

Due to the wide range of variability in behavior and life cycle demonstrated by 

each arthropod species, using a standard design for all host testing is 

unrealistic. Therefore, host testing for each proposed agent requires a slightly 

different and customized experimental design. The design used should be 

critically reviewed to determine if rigorous enough experimental standards 

were used and if adequate quality control was followed. 

Each design should be reviewed to determine adequacy and standardization of 

the following: 

Quality of host plant 

Quality of test arthropods 

Number of plants for each plant species tested 

Number of plant species used to represent a genus 

Number of arthropods tested 

Stage of arthropod used in the test 

Replication of tests 

Use of appropriate surrogate plant species in place of rare, threatened, or 

endangered native plant species 

Use of actual threatened and endangered species 

Conclusion 

The general process used in host specificity testing begins with field studies of 

the arthropod when the arthropod is first found and being considered as a 

potential biological control agent. 

The next step is to screen a large number of test plants to eliminate those 

species or groups that are not at risk. 

This is followed by further testing under more natural conditions that eliminate 

additional plant species and identify those that are possibly at risk of attack by 

the proposed biological control agent of weeds. At this point in the screening 

process only a few plant species require additional testing. These usually 

require much more complex and comprehensive tests to determine which 

could possibly be selected by females as a suitable host and can support natural 

development of the arthropod. 

The results of host testing are easy to evaluate if under several different test 

arrangements arthropods are found to feed and develop only on the target 

4-3-8 TAG-BCAW Manual 10/2023-05 
 

Conclusion 

weed. In this case, there is usually no question about host specificity. This 

situation is usually quite rare; if a realistic selection of test plants is used 

including many related species, then the arthropod is almost always found to 

have a host range of several species. 

In the past, if the other plants in the host specificity tests on which the 

arthropod fed and developed were weeds or were accidentally-introduced 

plants of no known value, then the release of the insect was usually approved. 

However, if the non-target plant attacked is a native species or a desirable 

agricultural or ornamental plant, then the researcher must demonstrate, based 

on phenology, climatic limits, or geographic range, why the proposed 

biological control agent of weeds will not utilize or at least not significantly 

damage, desirable plant species at a population level. 

Therefore, the most important parts of host specificity testing to relate to TAGBCAW and other reviewers are the petitioner’s explanation and interpretation 

of their results, and how they can be used to extrapolate the potential damage 

the proposed biological control agent of weeds may cause (should the 

proposed biological control agent be released) to nontarget plants, especially to 

threatened and endangered species. 

References 

For more information about host specificity testing of arthropods, see the 

following listed references as well as those listed in Testing Methodology for 

Biological Control on page F-25. 

Briese, D.T. 2002. The centrifugal phylogenetic method used to select plants for host-specificity 

testing of weed biological control agents: can and should it be modernised? In: Spafford Jacobs, 

H.; Briese, D.T. eds. Improving Selection, Testing, and Evaluation of Weed Biological Control 

Agents. Proceedings of the CRC for Australian Weed Management Biological Control of Weeds 

Symposium and Workshop; 2002 13 Sept.; University of Western Australia, Perth, Western 

Australia. Adelaide (Australia): CRC for Australian Weed Management, University of Adelaide; 

2003. p. 23-33 (CRC Technical Series #7). 

Briese, D.T. 2005. Translating host-specificity test results into the real world: the need to harmonise the yin and yang of current testing procedures. Biological Control 35: 208-214. 

Cullen, J.M. 1988. Current problems in host-specificity screening. In Delfosse, E.S. ed. Proceedings of the VII International Symposium of the Biological Control of Weeds; 1988 6-11 

March; Instituto Sperimentale per la Patologia Vegetale (MAF); Rome Italy. Melbourne (Australia): DISR/CSIRO; 1990. p. 27–36. 

Cullen, J.M. 1992?. Predicting effectiveness: fact and fantasy. In Delfosse, E.S.; Scott, R.R. 

eds. Proceedings of the VIII International Symposium on Biological Control of Weeds; 1992 

February 2-7; Lincoln University, Canterbury, New Zealand. Melbourne (Australia). DSIR/ 

CSIRO; 1995? p:103-109. 

De Clerck-Floate, R.; Hinz, H.L.; Herd, T.; Julien, M.; Wardill, T.; Cook, C. 2007. Preliminary 

results of a survey on the role of arthropod rearing in classical weed biological control. In Julien, 

M.H.; Sforza, R.; Bon, M.C.; Evans, H.C.; Hatcher, P.E.; Hinz, H.L.; Rector, B.G., eds. Proceed10/2023-05 TAG-BCAW Manual 4-3-9 
 

 

 

 

Conclusion 

ings of the XII International Symposium on Biological Control of Weeds; 2007 April 22-27; La 

Grande Motte, France. Walingford, Oxfordshire (UK): CAB International; 2008. p. 536-542. 

Dunn, P.H. 1976. Shortcomings in classic tests of candidate insects of the biocontrol of weeds. 

In Freeman, T.E. ed. Proceedings of the IV International Symposium on Biological Control of 

Weeds; 1976 Aug 30-Sept 2; University of Florida, Gainesville, Florida. Gainesville (Florida): 

University of Florida Institute of Food and Agricultural Sciences; 1976. p. 51–56. 

Harris, P.; Zwölfer, H. 1968. Screening phytophagous insects for biological control of weeds. 

Canadian. Entomologist. 100:295–303 

Harris, P.; McEvoy, P. 1992. The predictability of insect host plant utilization from feeding tests 

and suggested improvements for screening weed biological control agents. In: Delfosse, E.S.; 

Scott, R.R. eds. Proceedings of the VIII International Symposium on Biological Control of 

Weeds; 1992 February 2-7; Lincoln University, Canterbury, New Zealand. Melbourne (Australia): DSIR/CSIRO; 1995. p. 125–131. 

Julien, M.; McFadyen, R.E.C.; Cullen, J. eds. 2012. Biological Control of Weeds in Australia. 

Melbourne (Australia): CSIRO Publishing. 648 p. 

McEvoy P.B. 1996. Host specificity and biological pest control. BioScience 46: 401-405. 

McFadyen, R.E.C. 1998 Biological control of weeds. Annual Review of Entomology 43: 369-93. 

Schaffner, U. 2001. Host range testing of insects for biological weed control: How can it be better interpreted? BioScience 51: 951-959. 

Shepherd, R. C.H. 1990. Problems which arise with host-specificity testing of arthropods. In: 

Delfosse, E.S., ed.Proceedings of the VII International Symposium on Biological Control of 

Weeds; 1988 6–11 March; Instituto Sperimentale per la Patologia Vegetale (MAF); Rome, Italy. 

Melbourne (Australia) DISR./CSIRO; 1990.p. 85–92. 

Spafford-Jacob, H.; Birese, D.T. (eds.) 2003. Improving the Selection, Testing, and Evaluation of 

Weed Biological Control Agents. CRC for Australian Weed Management, Technical Series #7, 

CRC Weed Management, Adelaide, Australia. 

Van Driesche, R.; Heard, T.; McClay, A.; Reardon, R., technical editors. 1999. Proceedings of 

Session: Host Specificity Testing of Exotic Arthropod Biological Control Agents—The Biological 

Basis for Improvement in Safety. X International Symposium on Biological Control of Weeds; 

1999 4-14 July; Montana State University, Bozeman, Montana. Morgantown (West Virginia): 

United States Department of Agriculture, Forest Service, Forest Health Technology Enterprise 

Team; 2000. 95 p. (FHTET-99-1). 

Van Klinken, R.D.; Edwards, O.R. 2002. Is host specificity of weed biological control agents 

likely to evolve rapidly following establishment? Ecology Letters 5: 590-596. 

Wapshere, A.J. 1974a. Host specificity of phytophagous organisms and the evolutionary centres of plant genera or sub-genera. Entomophaga 19: 301–309. 

Wapshere, A.J. 1974b. A strategy for evaluating the safety of organisms for biological weed 

control. Annals Applied Biology 77: 201–211. 

Withers, T.M.; Barton Brown, L.; Stanley, J. (eds.) 1999. Host Specificity Testing in Australasia: 

Towards Improved Assays for Biological Control. Scientific Publications, QLD DNR, Coorparoo, 

Australia. 

Zwölfer, H.; Harris, P. 1971. Host specificity determination of arthropod for biological control of 

weeds. Annual Review of Entomology 16: 159–178. 

4-3-10 TAG-BCAW Manual 10/2023-05 
Chapter 

4 Biological Control of 

Weeds 

Host Specificity Testing of Pathogens 

Contents 

Introduction 4-4-1 

Host Specificity Testing 4-4-1 

Protocols and Conditions for Host Specificity Testing 4-4-2 

Physiological Conditions 4-4-2 

Positive Control 4-4-3 

Host Plant Selection 4-4-3 

Condition of Test Plants 4-4-3 

Growing Conditions 4-4-4 

Inoculation Route and Method 4-4-4 

Techniques Used for Rating Disease 4-4-4 

Disease Symptoms on Nontarget Hosts 4-4-5 

Field Trials 4-4-6 

Environmental Conditions 4-4-6 

Physiological Stage of Test Plants 4-4-7 

Controls 4-4-7 

Introduction 

The Host Specificity Testing of Pathogens section of the Biological Control of 

Weeds chapter provides the guidelines for host specificity tests of pathogens 

that are proposed as biological control agents of weeds. These guidelines are to 

be read and looked over again by TAG-BCAW members before reviewing and 

evaluating submitted petitions. 

Host Specificity Testing 

Host specificity testing of pathogens proposed as biological control agents of 

weeds (hereafter referred to as pathogens) must initially take place under 

controlled environmental conditions. Frequently these studies are conducted in 

greenhouses or growth chambers and in quarantine. The use of dew chambers 

to facilitate fungal infection under controlled conditions is commonplace. 

The wide range of problems encountered in raising plants under such 

conditions might complicate the analysis of test results. A test under conditions 

that heavily favors disease is the first step to conclude that a negative is a 

10/2023-05 TAG-BCAW Manual 4-4-1 
Protocols and Conditions for Host Specificity Testing 

negative. Then more detailed, quantitative experiments (statistics, etc.) are 

conducted to clarify what a “non-target effect” actually means. It has been 

shown that cuticle properties etc., can be different under artificial conditions, 

leaving plants more susceptible to pathogen attack, and sometimes leading to 

false positives. Since the cuticle is the primary barrier to infection from foliar 

pathogens, this may confound results. Therefore, studies conducted in a 

quarantine facility, with artificial light simulating natural light conditions 

(daylight, dusk/dawn), would be more approximate of natural conditions. 

Many greenhouse coverings exclude ultra-violet light (UV), which when 

present (as under field conditions) has been shown to be detrimental to many 

types of pathogens. UV light is known to trigger the production of enzymes in 

plants that are involved in the immune response to pathogen attack. Hence, 

field grown plants are often pre-adapted to ward off pathogenic attack. 

Protocols and Conditions for Host Specificity Testing 

Ascertaining optimum conditions for disease of a target weed is important 

prior to initiating host range experiments. Although determining optimum 

conditions for disease may be a lengthy process, it provides the foundation for 

host range determinations. 

Factors that need to be considered include the following: 

Inoculum application method; 

Carrier and adjuvants for inoculum application; 

Concentration of inoculum in the carrier; 

Total volume of carrier plus inoculum to be applied; 

Requirement of the pathogen for free water on the leaf surface (dew 

period); 

Temperature during dew period and length of dew period; and 

Temperature of growth chamber after dew period. 

Physiological Conditions 

The physiological condition of the test plants at the time of pathogen 

inoculation is an important consideration and should be described in the 

petition. This is often described by the number of leaves at the time of 

application. Size of the plant, especially height, is a poor indicator since young 

plants that are exposed to low light levels might be taller than older plants that 

were grown under high light conditions. Reproductive status of the plants 

(phenological stage) may also be useful to note. Part of the plant inoculated, 

e.g., top or bottom surface of the leaf, is also important to document. 

4-4-2 TAG-BCAW Manual 10/2023-05 
Positive Control 

Positive Control 

The petition may not necessarily contain the details of how all the preceding 

experiments were carried out, as long as the petition clearly shows these 

factors have been considered. 

A positive control is one that is reasonably expected to give a positive 

response. When the researcher uses a positive control in the host specificity 

tests, the reviewer can be certain that the researcher is striving for evidence that 

conditions were favorable for disease and that the pathogen was functional. 

In the case of a host specificity test, the target weed with a suitable number of 

replicates must be included in all tests. If the pathogen is a compatible agent, 

then the target weed will exhibit a strong reaction to the pathogen. 

Susceptibility of biotypes of the target weed needs to be established before host 

specificity testing is conducted. A representative biotype can then be used as 

the positive control in subsequent tests. 

Host Plant Selection 

A strategy based on the Wapshere centrifugal method for selecting plants for 

host specificity testing is covered under Test Plant Lists on page 5-1. Another 

approach is Berner et. al.’s mixed model analysis combining disease ratings 

and DNA sequences to determine the host range of a pathogen and the use of 

best linear unbiased prediction (BLUPs) of pathogen host range. Another 

method takes into account the pathogen’s biology (e.g., a rust fungus with 

primary and alternate hosts in phylogenetically distinct families, host range 

models based on the known hosts of facultative saprophytes, etc.). Other 

systems, such as Briese’s proposed plant molecular systematics method may 

also be used. 

The identity of the plants must be confirmed, the person identifying the plants 

must be named, and the source of propagative material must be clearly stated. 

Condition of Test Plants 

The petitioner should thoroughly describe the conditions under which the test 

plants were grown. Actively growing plants that are free of arthropods and 

diseases (i.e., healthy), and that are in a good physiological condition should be 

used. Where possible, testing leaves of different ages would be advantageous 

within the same replicate. 

The petitioner should describe the phenological stage of test plants (seedlings, 

vegetative buds, flowers, fruit, seeds). Watering and fertility regimes should be 

10/2023-05 TAG-BCAW Manual 4-4-3 
Growing Conditions 

described, as well as the type and size of containers used. The type of soil used 

in the pots should be adequately described, since sterile soil can eliminate 

possible beneficial species that can directly affect susceptibility of plants to 

diseases such as Trichoderma spp. Large plants in small containers often 

experience nutrient and water stress if application of these factors is not 

frequent enough. Plants that have undergone such stress have activated enzyme 

systems that can be part of the immune response to pathogenic attack. 

Growing Conditions 

The growing conditions in the growth facility should be monitored and 

reported in an appendix to the petition. Critical factors are maximum and 

minimum air temperatures, duration of these temperatures, and periodic 

(hourly if possible) reporting of relative humidity, and light spectrum under 

which the plants were grown. If the petition clearly indicates that these factors 

were considered, then reporting all of these values in the petition may not be 

essential. 

Inoculation Route and Method 

The inoculation route (through soil for root pathogens, foliar spray for aerial 

pathogens, etc.) and inoculation method (use of surfactants, abrasives, 

wounding, placing inoculated plants under plastic cover, etc.) should be 

described. The reviewer should be able to assess whether proper route and 

method of inoculation was used. 

Techniques Used for Rating Disease 

Another important aspect of host specificity testing is a thorough description of 

the techniques used for rating disease. Disease incidence and severity should 

be considered. Incidence is the presence or absence of visual symptoms. 

Severity involves qualitative and quantitative measures of extent of disease 

presence. Macroscopic and microscopic evaluation of the infection provides 

the researcher with a key to use to evaluate any non-target symptoms. 

Since there are qualitative factors that must be considered, the petition should 

clearly state what those factors are and how the researcher made the 

evaluations. Qualitative determinations should be confirmed by some 

quantitative measure. Macroscopic measurement may be as simple as 

determining density by counting the number of fungal lesions per leaf and 

dividing by the size of the leaf. Qualitative terms such as small, medium, and 

large should be defined in quantitative terms (e.g. 0 to 5 mm, 6 to 10 mm, and 

>10 mm, respectively). Microscopic measurement which may consist of B&H 

staining of leaves from initial inoculation to expression enables observation of 

4-4-4 TAG-BCAW Manual 10/2023-05 
Disease Symptoms on Nontarget Hosts 

a compatible reaction compared to a hypersensitive reaction. Whatever 

measures are used, the technique should be thoroughly described. 

In judging whether the rating system is adequate, the reviewer should 

determine whether the petition describes the techniques in enough detail that 

the reviewer could repeat the procedure. The reviewer should then visualize 

the procedure and make a determination as to whether the techniques 

employed would yield an accurate picture of the presence and severity of 

disease. The use of long-accepted techniques, described in a significant body 

of literature, can help satisfy the reviewer that the techniques are adequate. 

When well-documented techniques have been used, they should be described 

in the petition in enough detail to allow those unfamiliar with the literature to 

visualize what was done. Citations should also be given for those who want to 

read more. 

Disease Symptoms on Nontarget Hosts 

In many cases, plant species other than the target weed will exhibit some 

disease symptomatology when challenged with a pathogen under ideal 

environmental conditions. Those that do not can be dropped from further 

testing. 

A phased approach may be used. The first phase is simply plus-and-minus 

to identify those plant species that are not susceptible to get an idea about 

amounts of disease on potentially susceptible non-targets. The second phase 

consists of detailed, quantitative if possible, experiments to describe what the 

disease response means in terms of damage to the non-target. 

Another approach is to run side-by-side comparative studies that include a 

relative of the proposed biological control agent of weeds already in the U.S. 

or a pathogen on the non-target that is already in the U.S. Infection may occur, 

but pathogen reproduction may not. This is probably acceptable level of risk, 

depending on the plant species. If the plant so affected is an endangered or 

threatened species, then determining if the infection causes demonstrable 

damage to the plant, and stating this finding is desirable. Such damage might 

be a reduction in growth rate, a reduction in flowering, or a reduction in 

viability of dispersal organs, such as seeds. However, it should be noted that 

artificial conditions might favor leaf drop or plants that might never flower 

under greenhouse conditions, and hence assessments obtained under such 

situations would be dubious. 

In another scenario, a small amount of pathogen reproduction may occur, but 

no or little secondary infection might take place, indicating that the pathogen 

would not be able to sustain a population on the non-target species. This may 

be acceptable risk, but further experimentation is probably prudent in this 

10/2023-05 TAG-BCAW Manual 4-4-5 
Field Trials 

situation. Inocula can be collected from this type of infection and used in 

studies to determine whether the inoculum is viable and infective. If the 

inoculum is not infective, then the risk is probably acceptable. 

A measurable secondary infection may occur on nontarget hosts. In this 

situation, further experimentation is needed. If practical, then field trials 

(overseas is permissible) can provide insight as to whether these limited types 

of infection have serious environmental and ecological implications for 

nontarget plant hosts. 

Field Trials 

Field trials should be conducted under conditions that favor the growth of the 

test plants. These conditions should be completely described and should 

include the following: 

Fertility and irrigation regimes 

Location of the test site 

Planting methods, including between row and within row spacing 

Soil type 

Time of year 

In the case of exotic pathogens, these trials will be conducted overseas within 

the native range of the pathogen (ideally in a location climatically similar to 

that of the intended release area), before approval for release from quarantine. 

Environmental Conditions 

Environmental conditions during the growth of the test plants, at the time of 

inoculation, and during the evaluation period should be monitored and 

reported. The following factors are important to include: 

Atmospheric humidity 

Rainfall data 

Maximum and minimum air temperature 

Soil temperature 

Solar radiation (indications of photoperiod and cloud cover) 

Wind speed 

4-4-6 TAG-BCAW Manual 10/2023-05 
 

Physiological Stage of Test Plants 

Physiological Stage of Test Plants 

The physiological stage of all test plants at the time of inoculation should be 

indicated. 

Controls 

As with controlled environment studies, positive controls should be included. 

The procedure for evaluating disease should be defined as for controlled 

environment studies. 

References 

For more information about host specificity testing of pathogens, refer to the 

following listed references as well as those listed inTesting Methodology for 

Biological Control on page F-25. 

Barton (nee Fröhlich), J. 2004. How good are we at predicting the field host-range of fungal 

pathogens used for classical biological control of weeds? Biological Control 31: 99-122. 

Barton, J. 2011. Predictability of pathogen host range in classical biological control of weeds: an 

update. BioControl DOI 10.1007/s10526-011-9401-7. 

Baudoin, A.B.A.M.; Abad, R.G.; Kok, L.T.; Bruckart, W.L. 1993. Field evaluation of Puccinia cardourum for biological control of musk thistle. Biological Control 3: 53-60. 

Berner, D.K. 2010. BLUP, a new paradigm in host-range determination. Biological Control 53: 

143-152. 

Berner, D.K.; Bruckart, W.L. 2005. A decision tree for evaluation of exotic plant pathogens for 

classical biological control of introduced weeds. Biological Control 34: 222-232. 

Berner, D.K.; Bruckart, W.L.; Cavin, C.A.; Michael, J.L. 2009. Mixed model analysis combining 

disease ratings and DNA sequences to determine host range of Uromyces salsolae for biological control of Russian thistle. Biological Control 49: 68-76. 

Berner, D.K.; Bruckart, W.L.; Cavin, C.A.; Michael, J.L.; Carter, M.L.; Luster, D.G. 2009. Best linear unbiased prediction of host-range of the facultative parasite Colletotrichum gloeosporioides 

f. sp. salsolae, a potential biological control agent of Russian thistle. Biological Control 51: 158-

168. 

Briese, D.T. 2003. The centrifugal phylogenetic method used to select plants for host-specificity 

testing of weed biological control agents: can and should it be modernised? In: Improving the 

Selection, Testing and Evaluation of Weed Biological Control Agents. CRC. Technol. Ser. No. 7, 

pp. 23-33. 

Bruckart, W.L. 1989. Host range determination of Puccinia jaceae from yellow starthistle. Plant 

Disease 73: 155-160. 

Bruckart, W.L. 1999. A simple quantitative procedure for inoculation of safflower with teliospores 

of the rust fungus, Puccinia carthami. Plant Disease 83: 181-185. 

Bruckart, W.L. 2004. Supplemental risk evaluations and status of Puccinia carduorum for biological control of musk thistle. Biological Control 32: 348-355. 

Bruckart, W.L. 2006. Supplemental risk evaluations of Puccinia jaceae var. solstitialis for biological control of yellow starthistle. Biological Control 37: 359-366. 

10/2023-05 TAG-BCAW Manual 4-4-7 
 

 

 

Controls 

Bruckart, W.L.,F. Eskandari,. 2002. Factors affecting germination of Puccinia jaceae var.solstitialis teliospores from yellow starthistle. Phytopathology 92:355-360. 

Bruckart, W.L.; Politis, D.J.; Defago, G.; Rosenthal, S.S.; Supkott, D.M. 1996. Susceptibility of 

Carduus, Cirsium, and Cynara species artificially inoculated with Puccinia carduorum from 

musk thistle. Biological Control 6: 215–221. 

Cook, et al. 1989. Safety of microorganisms intended for pest and plant disease control: a frame 

work for scientific evaluation. Biological Control 7: 333–351. 

Cullen, J.M. 1989. Current problems in host-specificity screening: Proceedings of VII International Symposium on Biological Control of Weeds; Rome, Italy: 27–36. 

Drea, John J., Jr. 1991. The philosophy, procedures, and cost of developing a classical biological control of weeds project. Natural Areas Journal 11(3): 143–147. 

Ellison, C.A.; Pereira, J.M.; Thomas, S.E.; Barreto, R.W.; and Evans, H.C. 2006. Studies on the 

rust Prospodium tuberculatum, a new classical biological control agent released against the 

invasive alien weed Lantana camara in Australia. 1. Life-cycle and infection parameters. Australasian Plant Pathology. 35: 309-319. 

Evans, H.C. Tomley, A.J. 1994 Studies on the rust, Maravalia cryptostegiae, a potential biological control agent of rubber-vine weed, Cyptostegia grandiflora (Asclepiadaceae: Periplocoideae), in Australia, III: Host range. Mycopathologia 126: 93-108. 

Fiscus, El.L. 1998. Enzymes give plants UV Protection. Agricultural Research. October: p. 11. 

Goeden, R.D. 1983. Critique and revision of Harris’ scoring system for selection of insect agents 

in biological control of weeds. Protection Ecology 5: 287–301. 

Harley, K.L.S.; Furno, I.W. 1992. Assessing natural enemies in field studies. In: Biological control of weeds: a handbook for practitioners and students. Melbourne, Inkata Press. 

Harris, P.; McEvoy, P. 1995. The predictability of insect host plant utilization from feeding tests 

and suggested improvement for screening weed biological control agents: Proceedings of the 

Eighth International Symposium on Biological Control of Weeds: 125–31. 

Hasan, S.; Delfosse, E.S.; Aracil, E.; Lewis, R.C. 1992. Host-specificity of Uromyces heliotropii, 

a fungal agent for the biological control of common heliotrope (Heliotropium europaeum) in Australia. Annals of Applied Biology 121: 697–705. 

Politis, D.J.; Watson, A.K.; Bruckart, W.L. 1984. Susceptibility of musk thistle and related composites to Puccinia carduorum. Phytopathology 74: 876–9093. 

Thomas, S.E.; Ellison, C.A.; Tomley, A.J. 2006. Studies on the rust Prospodium tuberculatum, a 

new classical biological control agent released against the invasive alien weed Lantana camara 

in Australia. 2. Host range. Australasian Plant Pathology 35: 321-328. 

4-4-8 TAG-BCAW Manual 10/2023-05 
Format and Evaluation 

Petitions for Field Release Format 

Chapter 

5 

Contents 

Introduction 5-1-1 

Format for Petitions for Field Release 5-1-2 

Cover Page 5-1-3 

Summary 5-1-4 

Introduction 5-1-4 

Target Weed Information 5-1-5 

Biological Control Agent of Weeds Information 5-1-8 

Experimental Methodology and Analysis 5-1-11 

Results and Discussion 5-1-13 

Potential Environmental Impacts 5-1-15 

Petitioner’s Conclusion 5-1-16 

Introduction 

The Petitions for Field Release Format section of the Format and Evaluation 

chapter contains a guide for petitioners and researchers to follow when 

preparing a petition; and provides guidelines for TAG-BCAW members to 

follow when reviewing and evaluating petitions for the release of biological 

control agents of weeds. 

10/2023-05 TAG-BCAW Manual 5-1-1 
Format and Evaluation 

Format for Petitions for Field Release 

Format for Petitions for Field Release 

The petitioners and researchers will follow the format below when preparing a 

petition for biological control agent of weeds for field release. The information 

requested in this format is believed to best demonstrate the potential risks that 

might be involved in the proposed biological control agent of weeds release 

and the long-term ecological consequences of a successful release. 

The format for the petition for field release contains the following main 

sections: 

Cover Page 

Summary 

Introduction 

Target Weed Information 

Biological Control Agent of Weeds Information 

Experimental Methodology and Analysis 

5-1-2 TAG-BCAW Manual 10/2023-05 
Format and Evaluation 

Cover Page 

Cover Page 

Prepare a cover page for the petition and include the following information on 

the cover page: 

1. Date of the petition and date of mailing. 

2. Name of the petitioner, affiliation, and contact information (petitioner’s 

address, email address, telephone number, fax number). 

3. Type of petition: Proposed field release of a [biological control agent] of a 

[target weed(s)]. Include order, family, genus, species, author, and 

geographical origin. 

A. If this petition represents additional information requested by the 

TAG-BCAW for a previously-submitted petition, then include the 

TAG-BCAW assigned number of the previous petition. 

B. If providing additional information requested by TAG-BCAW, then 

address only those sections indicated to be of concern to TAG-BCAW; 

and highlight the specific sections changed. Include a summary of the 

changes that were made. 

4. List of locations where the studies have been conducted. 

5. If part of the study has been conducted in a U.S. quarantine facility or 

facilities, then list the location of each quarantine facility. 

6. List the quarantine facility or facilities the petitioner intends the proposed 

biological control agent of weeds to pass through prior to initial North 

American releases. 

NOTICE 

Please be aware that pathogens will require a different type of quarantine facility 

than that used for arthropods. 

7. States or Provinces for initial release in the following countries: 

Canada 

Mexico 

United States 

8. Name(s) of those person(s), affiliation, and contact information (address, 

email address, telephone number, fax number) who will be conducting the 

release(s) and who will be monitoring the release(s) in North America. 

9. Confirmation of submission of specimens to each national collection as 

described on page 4-2-8 under Reference Collections. Please include a 

copy of the letter sent to each designation collections manager listed in 

Table 4-2-1, National Collections for Specimens. 

10/2023-05 TAG-BCAW Manual 5-1-3 
Format and Evaluation 

Summary 

Summary 

Include an abstract of the petition, with the following information in the 

summary: 

Problem 

Approach 

Main findings 

Introduction 

Include the following information in the petition’s introduction: 

Nature of the Problem 

Proposed Action 

Nature of the Problem 

Give a brief summary (one to two paragraphs) of the problem caused by the 

weed. 

Consider including in the following topics in the summary: 

History of introduction and/or spread of the target weed 

Pending issues about the following: 

Agent(s) 

Location of release 

Taxonomy of proposed biological control agent(s) of weeds 

Taxonomy of target weed 

Sectors affected and magnitude of program (e.g., agricultural, natural, 

rangeland) 

Target weed’s present distribution in North America 

Proposed Action 

Provide a statement of the proposed action. 

EXAMPLE Proposed action: To introduce a [biological control agent] from [a foreign 

area] for field release in [a specific area] to control [target weed] in [Canada, 

Mexico, the United States]. 

5-1-4 TAG-BCAW Manual 10/2023-05 
Format and Evaluation 

Target Weed Information 

Target Weed Information 

Often detailed information will have been provided in previously-submitted 

test plant lists or release petitions. This information can be repeated along with 

additional information in subsequent petitions for field release. 

Include the following under the petition’s Target Weed Information: 

Taxonomy 

Description 

Distribution of the Target Weed 

Taxonomically-Related Plants 

Distribution of Taxonomically-Related Plants 

Life History of the Target Weed 

Impacts of the Target Weed 

Management Options 

Taxonomy 

Include the following under Taxonomy: 

1. Full classification, synonymy, and common name; include order, family, 

genus, species. 

2. Cite experts who identified the target weed in North America (name, 

organizations, locations). 

3. List names of experts and publications confirming the presence of the 

target weed in North America. Include organizations, locations. 

4. Problems (and if possible, proposed resolutions) associated with the 

group’s identification or present taxonomy. 

5. Origin and location of herbaria containing voucher specimens, and the date 

of specimen deposit. The voucher specimens referred to here are those used 

as representatives of the population that occur in the area where the 

researcher has conducted the studies. 

Description 

Provide a general description of the target weed, complete enough that the 

correct identification could be made by a person encountering the weed in the 

field. 

10/2023-05 TAG-BCAW Manual 5-1-5 
Format and Evaluation 

Target Weed Information 

Distribution of the Target Weed 

Describe the distribution of the target weed and use maps, as appropriate. 

Include the following information: 

1. Map of Native range (map). 

2. Areas of introduction throughout the world (map), pattern of movement, 

and apparent limits. 

3. Present distribution areas in North America (map). 

4. Description of the target weed’s areas of potential spread in North 

America. 

5. Genetic and phenotypic variability with respect to geographic distribution. 

6. Habitats or ecosystems where this weed is found in North America. 

Taxonomically-Related Plants 

Include the following: 

1. Identify both native and non-native plants that are closely related to the 

target weed; 

2. Emphasize economically and environmentally important species; and 

3. Identify crops, ornamentals, and native plants including threatened and 

endangered species and those with cultural or aesthetic value 

If possible, identify how closely these plants are related to the target 

weed; and 

If applicable, include identified surrogates. 

Distribution of Taxonomically-Related Plants 

Describe the distribution and habitats in North America of the taxonomicallyrelated plants identified under Taxonomically-Related Plants above. 

Life History of the Target Weed 

Explain the life history and general biology of the target weed. Discuss the 

factors that are believed to contribute to the plant’s weediness. 

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Format and Evaluation 

Target Weed Information 

Impacts of the Target Weed 

Indicate any and all impacts made by the target weed. Include any potential 

conflicts. Use the following list as a guide (not all areas listed below are 

applicable to all petitions): 

1. Beneficial uses—honey bees, forage, ground cover, fruit, etc. 

2. Social and recreational impacts—value as ornamentals or other. 

3. Impact on threatened and endangered species. 

4. Economic losses, including direct control costs. 

5. Health—poisonous, allergenic. 

6. Regulatory—noxious weed, restricts trade. 

7. Effects on native plant and animal populations. 

8. Impact of weed control on nontarget plants. 

9. Effects on ecosystem functions and ecological relationships. 

10. Other, e.g., aesthetic. 

Management Options 

Describe options for managing the target weed. 

1. Historical options—what has been done before and its effectiveness. 

2. Current options—biological, chemical, cultural, etc., and effectiveness. 

3. Potential options—new herbicides or biological control agents used or 

released in other countries. 

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Format and Evaluation 

Biological Control Agent of Weeds Information 

Biological Control Agent of Weeds Information 

Include the following under Biological Control Agent Information: 

NOTICE 

If a petition concerning this agent has been previously submitted, then state when 

and where. Be sure the previously-identified TAG-BCAW concerns are 

adequately addressed in this submission. Highlight the changes. 

Taxonomy 

Geographical Range 

Known Host Specificity 

Life History 

Population of the Biological Control Agent Studied 

Taxonomy 

Include the following under Taxonomy: 

1. Full classification (order, family, genus, species), synonymy, and common 

names. For pathogens, also include strain, race, or other specific 

designation (e.g. isolate number, pathovar, etc.). 

2. A general description of the proposed biological control agent, including 

helpful morphology and diagnostic characteristics that could be used to 

identify the agent in the field. 

3. Method for distinguishing the proposed biological control agent in the field 

and in quarantine (e.g., how the proposed biological control agent will be 

discriminated from existing related organisms and antagonistic, cryptic, or 

competing species). 

4. Reason for choosing the proposed biological control agent. 

5. Taxonomic expert who identified the proposed biological control agent, 

including the expert’s name(s), address, email address, and affiliations 

(with locations). 

6. Problems with identification or with taxonomy. Include citations 

referencing the issues. 

7. For arthropods and pathogens: the origin and locations of voucher 

specimens, date of specimen deposit, and how the voucher specimens are 

preserved. 

8. For arthropods and pathogens: a description of the methods used to identify 

life stages. 

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Format and Evaluation 

Biological Control Agent of Weeds Information 

9. For arthropods and pathogens: If available, DNA analysis or other 

molecular evaluation. 

10. For arthropods and pathogens: Identification/characterization information 

used to confirm the determination during the evaluation processes and 

during field colonization efforts overseas. 

Geographical Range 

Include the following under Geographic Range: 

1. Origin of the proposed biological control agent—maps and literature 

citations describing the native range of the agent. 

2. If the proposed biological control agent is being used in other countries, 

then give the names of countries (ISO country names) of introduction and 

present range and known site efficacy. 

3. Expected, attainable range of the biological control agent outside the area 

proposed for initial release in North America—based on climatic, 

environmental, and vegetative preferences of the proposed biological 

control agent. 

Known Host Specificity 

Include the following under Known Host Specificity: 

1. Literature records indicating other host plants that have been attacked by 

the proposed biological control agent. 

2. Field host-plant collections and observations of the biological control agent 

in the area of origin, including maps and data. 

3. Literature records known host plant specificity of organisms closely related 

to the biological control agent, no matter where the organisms occur. 

Life History 

Include the following under Life History: 

1. Basic biology and life history of the proposed biological control agent (i.e., 

diapause, resting stages, life cycle, dispersal capability, overwintering, etc. 

from literature, field observations, and laboratory studies) in enough detail 

to explain the agent’s role in the new environment. 

2. Known mortality factors. 

3. Extent of damage to or control of the target weed. 

4. Extent of damage to or impact on nontarget plants and other organisms. 

10/2023-05 TAG-BCAW Manual 5-1-9 
Format and Evaluation 

Biological Control Agent of Weeds Information 

Population of the Biological Control Agent Studied 

Include the following under Population of Biological Control Agent Studied: 

1. Geographical source(s) (origin) of the biological control agent. If available, 

include a map and site description. Be as accurate as possible so that the 

same population can be located if needed. 

2. How a pest-free population of the proposed biological control agent was 

obtained and maintained in quarantine if applicable. 

3. Biological control agent studied for the initial release is from the same 

population used for the studies or the biological control agent for release is 

identical to those tested (genetic or morphological confirmation). 

4. Locations of field studies, lab studies, and quarantine facilities. 

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Format and Evaluation 

Experimental Methodology and Analysis 

Experimental Methodology and Analysis 

Include the following under Experimental Methodology and Analysis section: 

Test Plant List 

Design 

Positive Controls 

Rationale for Study Design and Execution 

Test Plant List 

Often a new biological control agent will require alteration of a previouslyapproved test plant list. If this is the case, then so state and identify and explain 

the rationale and changes. Include the host test plant list, even if no changes 

were made. 

NOTICE 

 

If an acceptable test plant list was already prepared and reviewed by TAG-BCAW 

prior to preparing the petition, then so state under the Test Plant List heading. 

Highlight any changes made to the test plant list. 

If a test plant list has not already been prepared and reviewed by TAG-BCAW 

prior to preparing the petition, then list the test plant(s) and provide the 

rationale for selecting the plants. 

1. List the species of host plants on which the proposed biological control 

agent was tested. 

2. Explain why the listed plant species were chosen to determine the potential 

feeding range of the proposed biological control agent. 

3. Include considerations given to threatened and endangered plant species 

and economically important plants. 

4. See the required Test Plant List Format on page 5-1. Follow this format to 

help ensure that host specificity of the agent is properly circumscribed. 

5. See ESA Compliance on page 6-1 for guidelines to comply with 

Section 7 and to expedite any review necessary because of protected 

species. 

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Format and Evaluation 

Experimental Methodology and Analysis 

Design 

Include the following under Design: 

1. Plant parts and growth stages of all plants tested. 

2. Source population of the test plants and target weed used in the test. 

3. Number of replicates. 

4. Number, stage, and age (arthropods) or phase (pathogens) of individual 

agents including number of males and females (arthropods), target weeds, 

and test plants in each replicate. May be synonymous with number of 

replicates depending on test design (i.e., in no-choice tests, the number of 

individual plants of a species is the number of replicates). 

5. Details of experimental setup pertaining to overall environmental 

conditions and study areas. 

6. How data were measured, recorded, and evaluated. Include statistical 

methods used. 

Positive Controls 

Indicate, under Positive Controls, how appropriate positive controls were used 

in all tests. Target is present at every step in the test process. 

NOTICE 

The target weed should be challenged with the proposed biological control agent 

before each testing procedure. 

Rationale for Study Design and Execution 

Include under Rationale for Study Design and Execution, an explanation of 

why the test procedures were selected and how they are appropriate for the 

biology of the agent being tested. 

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Format and Evaluation 

Results and Discussion 

Results and Discussion 

Include the following under the Results and Discussion section: 

Summary of Results 

Protocol for Releasing the Proposed Biological Control Agent 

Post-Release Monitoring 

Benefits and Risks 

Summary of Results 

Provide a summary of the environmental impacts of this organism as a 

biological control agent and any risk associated with its release, including the 

following: 

1. Results in relation to host specificity and environmental impact. 

2. Relevant citations of related literature, results of host specificity testing, 

and field observations. 

3. Presenting results in a manner that supports the conclusion (tables, graphs, 

narratives). 

Protocol for Releasing the Proposed Biological Control 

Agent 

Include the following under Protocol for Releasing the Proposed Biological 

Control Agent: 

1. Methods used to ensure pure cultures and correct identification of the 

proposed biological control agent to be released, including the following: 

A. For arthropods: species, genus, family, and order. 

B. For pathogens: strain, race, or other specific designation, e.g. isolate 

number, pathovar, etc. (Make consistent with above.) 

C. Names, affiliations, and locations of identifiers. 

(Make consistent with above.) 

D. Description of identification methods. 

E. Problems in identification. 

F. Date and place of depository containing voucher specimens. 

2. General release protocol to ensure the absence of natural enemies and 

cryptic or sibling species. 

3. Specific location of rearing or culturing facility. 

4. Intended sites (States or provinces) for initial release. Timing of release. 

Release methods to be used. 

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Format and Evaluation 

Results and Discussion 

A. For arthropods: if known, the number to be released. 

B. For pathogens: method of preparing inoculum and inoculum 

concentration. 

Post-Release Monitoring 

Include the following explanation of the post-release monitoring plan under 

Post-release Monitoring,: 

1. When the anticipated initial release of the proposed biological control 

agent(s) will occur. 

2. Groups to best perform monitoring. 

3. Monitoring techniques to determine if the proposed biological control 

agent(s) become established. 

4. Monitoring techniques to characterize the spread of the proposed 

biological control agent and the observed impact (if any) on target and 

nontarget plants or organisms. 

Benefits and Risks 

Include the following under Benefits and Risks: 

1. Provide a comprehensive statement that discloses all relevant known data 

gaps concerning the proposed biological control agent’s and the target 

weed’s biology and ecology. 

2. Include the factors that would reasonably influence the probable benefits or 

possible negative impacts of releasing the biological control agent. 

3. Give your perspective, weighing the probable benefits of releasing the 

agent against the risks associated with the agent. 

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Format and Evaluation 

Potential Environmental Impacts 

Potential Environmental Impacts 

Include the following under the Potential Environmental Impacts section: 

Human Impacts 

Economic Impacts 

Plant Impacts 

Nonplant Impacts 

Abiotic and Edaphic Impacts 

Methods for Mitigation 

Outcome of No Action 

Discuss and present a clear picture of the long-term ecological consequences 

that might result from the successful establishment of the proposed biological 

control agent in the North American environment. This discussion should go 

beyond the risk associated with attacks on a few closely-related species of 

plants, as indicated in the host testing results. The discussion should look at the 

overall potential impact of populations of this proposed biological control 

agent building up on the weed in a range of habitats. 

This information will be considered by APHIS in an environmental assessment 

(EA), before the Agency considers issuing a permit. 

Continue below. 

Human Impacts 

Include positive and negative impacts of the proposed biological control agent 

to humans. Discuss ways to mitigate negative effects. 

EXAMPLE Health, recreation, aesthetics, nuisance, poison, allergens. 

Economic Impacts 

Include a discussion of the potential gains and losses regarding the economic 

impacts of the proposed biological agent of weeds as follows: 

Aesthetic impacts 

Biological impacts 

Ecological impacts (such as on natural resources, components, structures, 

and functioning of affected ecosystems) 

Social impacts (such as cultural) 

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Format and Evaluation 

Petitioner’s Conclusion 

Plant Impacts 

Describe the value of proposed biological direct and indirect impacts (positive 

and negative) of the proposed biological control agent on the target plant 

population against impacts on nontarget plants. Cover the intended effects on 

the target weed and on nontargets, including potential impacts on agricultural, 

horticultural, and threatened and endangered plants. 

Abiotic and Edaphic Impacts 

Identify the potential abiotic and edaphic impacts of the proposed biological 

control agent on water, soil, and air resources. 

Nonplant Impacts 

Describe the indirect impacts (positive and negative) of the proposed 

biological control agent’s release on organisms (other than plants) associated 

with the target weed (directly or indirectly). 

Methods for Mitigation 

Identify the methods (management and other alternatives) to mitigate 

potentially undesired effects. Include how to control the proposed biological 

control agent if there is a problem. 

Outcome of No Action 

Provide a statement of potential outcomes if the proposed biological control 

agent is not released. 

Petitioner’s Conclusion 

Under the Petitioner’s Conclusion section, summarize all the results from your 

study of this proposed biological control agent, its host testing, and your 

evaluation of the potential environmental impact. Offer your conclusions on 

the potential risks and benefits regarding the consequences of releasing this 

proposed biological control agent and its successful establishment in the North 

American environment throughout the range of its target weed and susceptible 

nontarget hosts. If available, then include a quantitative risk assessment. 

5-1-16 TAG-BCAW Manual 10/2023-05 
Format and Evaluation 

Petitions for Field Release Evaluation 

Chapter 

5 

Contents 

Introduction 5-2-1 

Evaluation Guidelines—Petitions for Field Release 5-2-1 

Agency’s or Organization’s Perspective 5-2-2 

Questions or Concerns During Review and Evaluation 5-2-2 

Sending Petitions Out for Additional Comments 5-2-2 

Petitions for Field Release Checklist 5-2-2 

Recording Comments 5-2-3 

Reviewer’s Overall Recommendation 5-2-3 

Locating Target Weed Information 5-2-3 

Locating Biological Control Agent Information 5-2-4 

Locating Methods and Approaches Information 5-2-4 

Evaluation Checklist — Petitions for Field Release of Biological Control 

Agents of Weeds 5-2-5 

Reviewer’s Overall Recommendation Checklist 5-2-17 

Introduction 

The Petitions for Field Release Evaluation section of the Format and 

Evaluation chapter contains the guidelines for TAG-BCAW members 

reviewing and evaluating petitions for the release of biological control agents 

of weeds. Petitioners may use the Evaluation Checklist — Petitions for Field 

Release of Biological Control Agents of Weeds to double-check their petitions 

before submitting for review. 

Evaluation Guidelines—Petitions for Field Release 

TAG-BCAW members will follow these evaluation guides when reviewing 

and evaluating petitions for field release of biological control agents of weeds. 

Review the information in this section before using to the Evaluation Checklist 

— Petitions for Field Release of Biological Control Agents of Weeds on page 

5-2-5. 

Petitioners may use the Evaluation Checklist — Petitions for Field Release of 

Biological Control Agents of Weeds on page 5-2-5 to double-check their 

petitions for field release of a biological control agent prior to submitting the 

petitions to USDA-APHIS-PPQ. 

10/2023-05 TAG-BCAW Manual 5-2-1 
Evaluation Guidelines—Petitions for Field Release 

Agency’s or Organization’s Perspective 

TAG-BCAW members should fully understand their Agency’s or 

organization’s current perspective on biological control activities before 

reviewing the petition. See Agencies and Organizations’ Perspectives on page 

2-3-1 for brief summaries. 

Questions or Concerns During Review and Evaluation 

If a TAG-BCAW member reviewing a petition has questions or concerns that 

only the petitioner could answer or resolve, then the TAG-BCAW member 

should contact the petitioner directly. The TAG-BCAW member should notify 

the TAG-BCAW Chair of the question(s) asked and the petitioner’s answer(s) 

so other TAG -BCAW members can be kept informed in case they have similar 

questions. 

Sending Petitions Out for Additional Comments 

TAG-BCAW members reviewing petitions should proceed with sending 

petitions for additional comments as follows: 

1. Establish timelines for additional reviews, keeping in mind that the time 

frame for reviewing and evaluating petitions is 6 weeks. Allow time for 

any subject matter expert(s) to review and evaluate the petition, as well as 

for you to synthesize comments and recommend action. 

2. Decide whether to send the entire petition or a portion of the petition out 

for comments. 

3. Prepare a request for additional comments cover letter with the following 

information: 

A. Specific guidance on which part of the petition you need the subject 

matter expert(s) (SME) to review. 

B. Contact information in case the SMEs have questions or concerns. As a 

TAG-BCAW member, you should remain the individual who directly 

contacts the petitioner. 

C. Timeline of when you expect a reply from the SME(s). 

Petitions for Field Release Checklist 

Use the Evaluation Checklist — Petitions for Field Release of Biological 

Control Agents of Weeds (see example on page 5-2-5) to see how much of this 

information was addressed by the petitioner and how thoroughly each topic 

was covered in the petition for release of the proposed biological control agent. 

5-2-2 TAG-BCAW Manual 10/2023-05 
 

Evaluation Guidelines—Petitions for Field Release 

Recording Comments 

Each TAG-BCAW member reviewing a petition will record synthesized 

comments on a TAG-BCAW Reviewer's Comment Sheet for Petitions for the 

Release of Biological Control Agents of Weeds (see example on page B-1-2). If 

the petition was sent for additional review(s), then list the names and subject 

matter expert areas in Block E, Summary Comments (see example in Figure 

B-1-2 on page B-3). 

Reviewer’s Overall Recommendation 

After reviewing all sections of the Evaluation Guidelines—Petitions for Field 

Release and completing the Evaluation Checklist — Petitions for Field Release 

of Biological Control Agents of Weeds, each TAG-BCAW reviewer will then 

use the information to develop an overall evaluation and recommendation from 

their Agency’s or organization’s viewpoint on the TAG-BCAW Reviewer’s 

Comment Sheet - Petition for Field Release of Proposed Biological Control 

Agents of Weeds. 

Locating Target Weed Information 

For additional references about economic botany, host specificity, plant 

specification systems, plant taxonomy and distribution, protected species, or 

submitted petitions, see Table 5-2-1. 

Table 5-2-1 Where to Find More Information About Target Weeds 

If you need additional information or 

research references about: And: Then: 

Economic Botany GO to Economic Botany on page F-1-15 

Protected Species GO to Protected Species on page F-1-20 

Host Specificity Arthropods GO to Testing Methodology for Biological Control on page 

F-1-25 

Pathogens GO to Testing Methodology for Biological Control on page 

F-1-25 

Plant Classification Systems GO to Plant Classification System on page E-1-1 

Plant Taxonomy and Distribution GO to Testing Methodology for Biological Control on page 

F-1-25 

Submitted Petitions Current list GO to TAG-BCAW site 

Historical list GO to TAG-BCAW site 

10/2023-05 TAG-BCAW Manual 5-2-3 
 

 

 

Evaluation Guidelines—Petitions for Field Release 

Locating Biological Control Agent Information 

For additional research references about biological control agents, 

identification and characterization of agents, or host specificity, see 

Table 5-2-2. 

Table 5-2-2 Locating Biological Control Agent Information 

If you need information 

about: And: Then: 

Biological control agents GO to Biological Control Agents on page F-1-5 

Identification and 

characterization of agents 

GO to Identification and Characterization of Proposed 

Biological Control Agents of Weeds on page 4-2-1 and 

References on page F-1-1 

Host specificity Arthropods GO to Host Specificity Testing of Arthropods on page 4-3-1 

and References on page F-1-1 

Pathogens GO to Host Specificity Testing of Pathogens on page 4-4-1 

and Testing Methodology for Biological Control on page F-1-

25 

Locating Methods and Approaches Information 

For additional information about methods and approaches most commonly 

used by researchers, then see Table 5-2-3. 

Table 5-2-3 Locating Biological Control Agent Information 

If you need: And for: And: Then: 

Review basic information 

or research additional 

references 

Host specificity Arthropods GO to Host Specificity Testing on page 4-3-2 and 

Testing Methodology for Biological Control on page 

F-1-25 

Pathogens GO to Host Specificity Testing of Pathogens on page 

4-4-1 and Testing Methodology for Biological Control 

on page F-1-25 

Testing methodology for 

biological control 

operations 

GO to Testing Methodology for Biological Control on 

page F-1-25 

5-2-4 TAG-BCAW Manual 10/2023-05 
 

 

Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Evaluation Checklist — Petitions for Field Release of Biological 

Control Agents of Weeds 

Use the evaluation checklist in Table 5-2-4 to record how much of this 

information was addressed by the petitioner and how thoroughly each topic 

was covered in the petition for field release of the proposed biological control 

agent of weeds. 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation 

Petition Section Is the following information included? Yes No 

Cover page 

(see page 5-1-3) 

Date of petition and date of mailing 

Petitioner’s complete name, affiliation, and contact 

information (address, email address, telephone 

number, fax number) 

Type of Petition: Proposed biological control agent is 

clearly identified (order, family, genus, species, author, 

geographical origin); and target weed is clearly 

identified (order, family, genus, species, author, 

geographical origin) 

If petition is in response to additional information 

requested by TAG-BCAW, then original petition’s TAGBCAW assigned number 

If providing additional specific information requested 

by TAG-BCAW, then only the requested sections 

have been addressed and changed and highlighted; 

includes a summary of the changes made 

Locations where the studies have been conducted 

If part of the study has been conducted in a U.S. 

quarantine facility or facilities, then the location of 

each quarantine facility 

NOTICE 

Pathogens will require a different type of 

quarantine facility than used for arthropod agents. 

Quarantine facility or facilities petitioner intends the 

proposed biological control agent(s) to pass through 

prior to initial North American releases 

States or Provinces for initial release in Canada, 

Mexico, and/or United States 

Person’s name, affiliation, and contact information 

(address, email address, telephone number, fax 

number) who will be conducting the release and 

monitoring in North America 

10/2023-05 TAG-BCAW Manual 5-2-5 
 

 

 

 

 

 

 

Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Petition Section Is the following information included? Yes No 

Summary 

Introduction 

(see page 5-1-4) 

Nature of the 

Problem and 

Proposed Action 

(see page 5-1-4) 

Abstract of the petition with a summary of the problem, 

approach, and main findings 

TAG-BCAW Reviewers: The introduction of the 

petition should provide a quick overview of the nature 

of the problem and the petitioner’s proposed action 

1. Read the petition introduction 

2. Determine if you will need additional reviews by 

subject matter experts within your Agency or 

organization in order to formulate an informative 

recommendation from your Agency’s or 

organization’s perspective 

3. If you determine that you need additional reviews, 

then see Sending Petitions Out for Additional 

Comments on page 5-2-2 

4. If you do not need additional reviews, then review 

the petition following the guidelines in this checklist 

5. Use a TAG-BCAW Reviewer’s Comment Sheet - 

Petition for Field Release of Proposed Biological 

Control Agents of Weeds (example on page B-1-2) 

There are issues about the taxonomy for either the 

target weed or the biological control agent 

You need a subject matter expert to validate the 

taxonomic information—entomologist, biologist, 

botanist 

There are issues about the proposed biological control 

agent 

There are issues about the location of the release 

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Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Petition Section Is the following information included? Yes No 

Target Weed 

Information 

(see page 5-1-5) 

Taxonomy 

(see page 5-1-5) 

Description 

(see page 5-1-5) 

Distribution of the 

Target Weed 

(see page 5-1-6) 

TAG-BCAW Reviewers: If you need to review basic 

information or research additional references, then 

see Table 5-2-1 on page 5-2-3 

This weed is identified as having been previously 

targeted as either a previously submitted petition for 

field release of a biological control agent of weeds or a 

previously-submitted test plant list 

If a petition for field release of a biological control 

agent or a test plant list has been previously 

submitted, then this includes a discussion of how the 

weed information compares with previous discussions 

and the changes are highlighted 

Full classification (order, family, genus, species); 

synonymy, and common name 

Expert who identified the target weed in North America 

is cited (name, organization(s), and locations) 

Experts who confirmed the target weed’s presence in 

North America are listed (organizations and locations) 

Problems associated with the group’s identification or 

present taxonomy and proposed resolutions (if any) 

Origin and location of the herbaria containing voucher 

specimens and date of deposit 

General physical description of the target weed is 

complete enough that correct identification could be 

made by a person encountering the target weed in the 

field 

TAG-BCAW Reviewers: Distribution of Target Weed 

section should provide you with a sense of where the 

target weed will spread in North America 

Adequate description and map of native range 

Adequate description and map of the areas of 

introduction throughout the world, pattern of 

movement, and apparent limits 

Adequate description and map of the target weed’s 

present distribution in North America 

Adequate description and map of target weed’s areas 

of potential spread in North America 

Adequate description of genetic and phenotypic 

variability with respect geographic distribution 

Adequate description of the habitats or ecosystems 

where the weed is found in North America 

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Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Petition Section Is the following information included? Yes No 

Target Weed 

Information 

(see page 5-1-5) 

Taxonomically 

Related Plants 

(see page 5-1-6) 

Both native and non-native plants that are closely 

related to the target weed 

Emphasizes economically and environmentally 

important species 

Crops, ornamentals, and native plants including 

endangered or threatened species that are closely 

related to the target weed. If applicable, includes 

identified surrogates 

Adequate description of how closely these plants are 

related to the target weed 

Distribution of 

Taxonomically 

Related Plants 

(see page 5-1-6) 

Life History of the 

Target Weed 

(see page 5-1-6) 

Adequate description of the distribution and habitats in 

North America of those taxonomically related plants 

identified under Taxonomically Related Plants above

 If information is lacking, then add comments on the 

TAG-BCAW Reviewer’s Comment Sheet - Petition for 

Field Release of Proposed Biological Control Agents 

of Weeds on page B-1-2. Otherwise, see Reviewer’s 

Overall Recommendation Checklist on page 5-2-17 

Adequate explanation of life history of the target weed 

Adequate explanation of general biology of the target 

weed 

Discussion of factors that are believed to contribute to 

the plants weediness 

5-2-8 TAG-BCAW Manual 10/2023-05 
 

 

Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Petition Section Is the following information included? Yes No 

Target Weed 

Information 

(continued) 

(see page 5-1-5) 

Impacts of the Target 

Weed 

(see page 5-1-7) 

Management 

Options 

(see page 5-1-7) 

Information about the impacts and potential conflicts 

made by the target weed is helpful in evaluating the 

release of the proposed biological control agent of 

weeds. Use the following areas of impact as a guide 

when reviewing a petition. Not all areas listed below 

are applicable to all petitions 

Beneficial uses: honey bees, forage, ground cover, 

fruit, etc. 

Social and recreational impacts: valued as an 

ornamental or other 

Threatened or endangered species 

Economic losses, including direct control costs 

Health: poisonous, allergenic 

Regulatory: noxious weed, restricts trade 

Native plant populations and animal populations 

Weed control on nontarget plants 

Ecosystem functions and ecological relationships 

Other impacts (e.g., aesthetics) 

Historical options for managing the target weed; what 

has been done before and its effectiveness 

Current options: biological, chemical, cultural, and 

effectiveness 

Potential options: new herbicides, biological control 

agents used or released in other countries 

NOTICE 

Petitioner may not have information on new 

chemicals developed. 

10/2023-05 TAG-BCAW Manual 5-2-9 
 

 

 

 

 

Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Petition Section Is the following information included? Yes No 

Biological Control If you need to review basic information or research 

Agent Information additional references about biological control agents, 

(see page 5-1-8) then see Biological Control Agent of Weeds 

Information on page 5-1-8 

Taxonomy 

(see page 5-1-8) 

Petition concerning this agent has been previously 

submitted (when and where) 

If a petition concerning this agent has been previously 

submitted, then the previously-identified TAG-BCAW 

concerns have been adequately addressed in this 

latest submission and are highlighted 

Full classification: 

 For Arthropods (order, family, genus, species) synonymy, and common name 

 For Pathogens, also strain, race or other specific 

designation (isolate number, pathovar, etc.) 

General description of the proposed biological control 

agent of weeds, including morphology, and diagnostic 

characteristics that could be used to identify the 

proposed biological control agent in the field 

Reason for choosing this proposed biological control 

agent 

Taxonomic expert who identified the proposed 

biological control agent, expert’s information (name, 

address, email address, and affiliations with locations) 

Problems with identification or with taxonomy, 

including citations and referencing issues 

Look for reference of an authoritative identification 

Arthropods and pathogens: look for the origin and 

locations of voucher specimens, date of specimen 

deposit, how the voucher specimens are preserved 

More detail is needed because a complex or problem 

taxonomic group is involved 

Arthropods and pathogens: description of methods 

used to identify life stages 

Arthropods and pathogens: If available, then DNA 

analysis or other molecular evaluation is included 

(useful when differentiation among close taxonomic 

groups is difficult using standard morphometric 

techniques) 

Arthropods and pathogens: Voucher methods are 

appropriate to the taxa or level of science involved 

Arthropods and pathogens: location of the voucher 

specimens (recognized taxonomic institutions are the 

best sources for information about voucher 

specimens) 

5-2-10 TAG-BCAW Manual 10/2023-05 
 

 

 

 

 

 

 

 

Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Petition Section Is the following information included? Yes No 

Biological Control 

Agent Information 

(continued) 

(see page 5-1-8) 

Taxonomy 

(continued) 

(see page 5-1-8) 

Geographical Range 

(see page 5-1-9) 

Known Host 

Specificity (range) 

(see page 5-1-9) 

Arthropods and pathogens: Identification/ 

characterization information was used to confirm the 

determination during the evaluation processes 

(additional collections, long-term rearing, etc.) and 

during field colonization efforts overseas 

Method for distinguishing the proposed biological 

control agent in the field and in quarantine (e.g., how 

the agent will be discriminated from existing, related 

organisms from antagonistic, cryptic, or competing 

species) 

This section should provide you with a good 

understanding of the potential range of the biological 

control agent 

Adequate description of the native range of the 

biological control agent (maps and literature citations) 

Adequate description of the names of the countries 

(see list of ISO country codes; select “Country codes” 

followed by “Search”) where the proposed biological 

control agent has been introduced, its present range, 

and its known efficacy are shown 

Potential spread of the biological control agent outside 

the area proposed for the initial release in North 

America based on climatic, environmental, and 

vegetative parameters is shown 

This section should give you a good sense of other 

plants the agent utilizes in its native range 

Literature records indicating other host plants the 

proposed biological control agent is known to attack 

Field host-plant collections and observations of the 

biological control agent in the area of origin including 

maps and data 

Literature records for known host plants of organisms 

closely related to the biological control agent 

(regardless of where the organism occurs) 

10/2023-05 TAG-BCAW Manual 5-2-11 
 

 

 

 

 

 

 

 

 

Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Petition Section Is the following information included? Yes No 

Biological Control 

Agent Information 

(continued) 

(see page 5-1-8) 

Life History 

(see page 5-1-9) 

Population of the 

Agent Studied 

(see page 5-1-11) 

Information provided is specific to the proposed 

biological control agent (the importance of a biological 

control agent’s life history will vary) 

Basic biology and life history of the proposed 

biological control agent are provided in enough detail 

to explain the proposed biological control agent’s role 

in the new environment 

Known mortality factors 

Extent of damage to or control of the target weed 

Extent of damage to or impact on the nontarget plants 

and other organisms 

This section should provide adequate information to 

ensure compatibility in the conditions between the 

locations of the study site and of the potential release 

site 

Geographic source(s) (origin) of the biological control 

agent population is adequately described so the same 

population can be located if needed. A map and a 

description are included if available 

How a pest-free population of the proposed biological 

control agent was obtained and maintained in 

quarantine if applicable 

Biological control agent studied for the initial release is 

from the same population used for the studies or the 

biological control agent for release is identical to those 

tested (genetic or morphological confirmation) 

Locations of field studies, lab studies, and quarantine 

facilities 

5-2-12 TAG-BCAW Manual 10/2023-05 
Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Petition Section Is the following information included? Yes No 

 

 

 

 

 

Experimental The description (method and data) should be sufficient for someone who is 

Methodology and qualified to repeat the experiment. If you need more information about methods 

Analysis and approaches commonly used by research or to review basic information or 

research additional references, then see Table 5-2-3 on page 5-2-4 (see page 5-1-11) 

Test Plant List If an acceptable test plant list was already prepared 

and reviewed by TAG-BCAW prior to preparing the (see page 5-1-11) petition, then so states 

Identifies and explains the rationale and changes to 

the test plant list; changes are highlighted 

Includes the host test plant list, even if no changes 

were made 

Lists the species of host plants on which the proposed 

biological control agent was tested 

Explains why the listed host plant species were 

chosen to determine the proposed biological control 

agent’s potential feeding range 

Considerations are given to threatened and 

endangered species and economically important 

plants 

Design Petitioner provides the following information about the 

design of the tests (see page 5-1-12) 

Part and growth stage of the plants tested 

Source population of test plants and target weeds 

used in the tests 

Number of replicates 

Number and stage (arthropods) or phase (pathogens) 

of individual proposed biological control agents 

(number of males and number of females 

(arthropods), target weeds, and test plants in each 

replicate; these numbers may be synonymous 

depending on the test design (i.e., in no-choice tests, 

the number of individual plants of a species is the 

number of replicates) 

Details of the experimental setup pertaining to overall 

environmental conditions and study areas 

Explanation of how the data were measured, 

recorded, and evaluated and statistical methods used 

Positive Controls How appropriate positive controls were used in all 

tests (positive control is where the target is present at (see page 5-1-12) every step in the test process) 

Rationale for Study Explanation of why the test procedures were selected 

Design and and how they are appropriate for the biology of the 

Execution proposed biological control agent being tested 

(see page 5-1-12) 

10/2023-05 TAG-BCAW Manual 5-2-13 
 

 

 

 

 

 

 

Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Petition Section Is the following information included? Yes No 

Results and 

Discussion 

(see page 5-1-13) 

Summary of Results 

(see page 5-1-13) 

Protocol for 

Releasing the 

Proposed Biological 

Control Agent 

(see page 5-1-13) 

Results discussed in relation to host specificity and 

environmental impact 

Method of presentation is appropriate to show the 

results 

TAG-BCAW Reviewer: If the method of presentation is 

not appropriate to show the results, then contact the 

petitioner directly to ask for the results in another way 

that would help you better understand the results 

Interpretation and significance of the results may be 

different between arthropods and pathogens; as a 

TAG-BCAW reviewer, you reached the same 

conclusion as the petitioner through interpretation of 

the data 

Consider your Agency’s or organization’s concerns 

when evaluating this section of the petition 

Methods used for ensuring pure cultures and correct 

identification of the proposed biological control agent 

to be released 

Arthropods: species, genus, family, and order 

Pathogens: strain, race, or other specific designation, 

e.g. isolate number, pathovar, etc. 

(consistent with above) 

Names, affiliations, and locations of identifiers 

(consistent with above) 

Description of identification methods 

Problems in identification 

Date and place of depository containing voucher 

specimens 

General release protocol to ensure the absence of 

natural enemies and cryptic or sibling species 

Specific location of rearing or culturing facility 

Intended sites (States or provinces) for initial release 

Timing of release 

Release methods to be used 

Arthropods: if known, the number to be released 

Pathogens: method of preparing inoculum and 

inoculum concentration 

5-2-14 TAG-BCAW Manual 10/2023-05 
 

 

Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Petition Section Is the following information included? Yes No 

Results and 

Discussion 

(continued) 

(see page 5-1-13) 

Post Release 

Monitoring 

(see page 5-1-14) 

Benefits and Risks 

(see page 5-1-14) 

Plan for post-release monitoring 

Monitoring plan adequately describes how the spread 

and impact of the proposed biological control agent on 

the target weed and nontarget plants will be 

determined 

Monitoring plan adequately describes monitoring 

techniques to be used to determine if the biological 

control agent becomes established 

Monitoring plan adequately describes groups to best 

perform monitoring 

Comprehensive statement of potential benefits and 

risks associated with the agent 

Comprehensive statement discloses all relevant data 

gaps concerning the proposed biological control 

agent’s and the target weed’s biology and ecology that 

might reasonably influence the probable benefits or 

possible negative impacts of releasing the agent. 

See Risk Assessment on page F-1-21 for additional 

information 

10/2023-05 TAG-BCAW Manual 5-2-15 
Evaluation Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

Table 5-2-4 Checklist for Field Release of Biological Control Agent of Weeds Evaluation (continued) 

Potential 

Environmental 

Impacts 

The petitioner should present a clear picture of the long-term ecological 

consequences that might result from the successful establishment of the 

proposed biological control agent in the North American environment. The 

discussion should go beyond the risk associated with attacks on a few closelyrelated species of plants, as indicated in the host specificity testing results. The 

discussion should look at the overall potential impact of populations of the 

proposed biological control agent building up on the weed in a large variety of 

different habitats 

Human Impacts 

(see page 5-1-15 

Positive and negative impacts of the proposed 

biological control agent of weeds on humans 

considered 

Ways to mitigate any negative effects of the proposed 

biological control agent of weeds on humans 

Economic Impacts 

(see page 5-1-15) 

Gains and losses regarding the economic impacts: 

aesthetic impacts, biological impacts, ecological 

impacts (such as on natural resources, components, 

structures, and functioning of affected ecosystems), 

and social impacts (such as cultural) of the proposed 

biological control agent of weeds 

Plant Impacts 

(see page 5-1-16) 

Value of the proposed biological control agent of 

weeds introduction on target populations against 

impacts on nontarget plants, including potential 

impacts (positive and negative) on agricultural, 

horticultural, and threatened and endangered plants 

Nonplant impacts 

(see page 5-1-16) 

Positive and negative impacts (if any) of the proposed 

biological agent’s release to nonplant organisms 

associated with the target weed (directly or indirectly) 

Abiotic and Edaphic 

Effects 

(see page 5-1-16) 

Potential effects of the proposed biological control 

agent of weeds on water, soil, and air resources 

Methods for 

Mitigation 

(see page 5-1-16) 

Mitigative methods are identified for controlling the 

proposed biological control agent of weeds should a 

potential problem occur 

Outcome of No 

Action 

(see page 5-1-16) 

Statement of potential outcomes if the proposed 

biological control agent of weeds is not released 

Petitioner’s 

Conclusion 

Petitioner offers conclusions about the potential risks 

and benefits of releasing the proposed biological 

control agent of weeds 

Discussion includes the probability of successful 

establishment of the proposed biological control agent 

in the environment throughout the range of its target 

weed and susceptible nontarget hosts 

Quantitative risk assessment 

(a quantitative risk assessment is not necessary) 

Petition Section Is the following information included? Yes No 

 

 

 

 

 

 

5-2-16 TAG-BCAW Manual 10/2023-05 
 

 

 

’

Reviewer’s Overall Recommendation Checklist 

Reviewer’s Overall Recommendation Checklist 

After you have finished reviewing the petition and completing the Evaluation 

Checklist — Petitions for Field Release of Biological Control Agents of 

Weeds, provide an overall assessment of the following items in Table 5-2-5. 

Record your overall recommendation on the TAG-BCAW Reviewer’s 

Comment Sheet - Petition for Field Release of Proposed Biological Control 

Agents of Weeds. 

Table 5-2-5 TAG-BCAW Reviewer’s Overall Recommendation Checklist—Petitions for Field Release of 

Biological Control Agents of Weeds 

TAG-BCAW Reviewer s Recommendation Yes No 

Completeness and comprehensiveness in completing the sections of the petition 

Thoroughness in addressing your Agency’s or organization’s concerns: 

Were your concerns met 

If your concerns were not met, then provide a summary of your Agency’s or organization’s concerns and the reasoning behind them 

Confidence level in the testing conducted and the information presented about the use of the 

proposed biological control agent in the environment 

If you have concerns regarding the risk of releasing this agent in North America, then provide 

specific comments 

Recommendation of your Agency or Organization 

Provide the name, affiliation, telephone, fax, and 

email numbers of the reviewer 

Provide the name(s) of other subject matter 

experts who provided comments 

Provide the name(s) of other subject matter 

expert(s) 

Sign and date the Comment Sheet 

Send the completed TAG-BCAW Reviewer’s 

Comment Sheet for Petitions for the Release of 

Biological Control Agents of Weeds to the 

TAG-BCAW Chair through the TAG-BCAW 

Executive Secretary 

Mr. Gregg B. Goodman 

TAG-BCAW Executive Secretary 

USDA-APHIS-PPQ 

4700 River Road, Unit 133, Office 4C-01.48 

Riverdale, MD 20737 

Email: gregg.b.goodman@aphis.usda.gov 

Fax: 301-734-5269 

10/2023-05 TAG-BCAW Manual 5-2-17 
Reviewer’s Overall Recommendation Checklist 

5-2-18 TAG-BCAW Manual 10/2023-05 
Format and Evaluation 

Test Plant List Format 

Chapter 

5 

Contents 

Introduction 5-3-1 

Test Plant Lists 5-3-1 

Format for Test Plant Lists 5-3-2 

Cover Page 5-3-2 

Introduction to the Test Plant List 5-3-3 

Target Weed Information 5-3-3 

Test Plant List 5-3-6 

Summary Table 5-3-11 

Perspective of Risk 5-3-11 

Strategy for Developing a Test Plant List 5-3-12 

Introduction 

The Test Plant List Format section of the Format and Evaluation chapter 

provides the format for test plant lists for biological control agents of weeds in 

North America. 

Test Plant Lists 

Test plant lists are developed by researchers and petitioners for determining the 

host specificity of biological control agents of weeds in North America. The 

test plant list is done as a benefit to the researcher and as a tool to get input 

from Federal Agencies, whether there is benefit in doing research. This does 

not preclude the Federal Agencies from taking a look at the list included in the 

petitions when they come in. 

A test plant list should be submitted early in the study (before the petition is 

submitted), when a researcher or petitioner is proposing to target a new weed 

for biological control. 

When the petitioner submits a petition for field release of a proposed biological 

control agent of weeds, the petition will include an updated test plant list. The 

updated test plant list contains those plants actually tested based on the TAGBCAW’s evaluation of the original test plant list. (Submitting a test plant list 

early will allow researchers to understand concerns that various Federal 

Agencies have in relation to the target and nontarget plants or other organisms. 

10/2023-05 TAG-BCAW Manual 5-3-1 
Format for Test Plant Lists 

Preliminary information about a target weed and a proposed biological control 

agent of weeds may be incomplete at this point in the research. The proposed 

test plant list may comprise the majority of the available information. 

Format for Test Plant Lists 

The format for the test plant list is as follows: 

Cover Page 

Introduction to the Test Plant List 

Target Weed Information 

Test Plant List 

Summary Table 

Perspective of Risk 

Cover Page 

Prepare a cover page for the test plant list with the following information. This 

information provides the TAG-BCAW with a contact point for questions and 

with references for tracking. 

Include the following information on the cover page: 

1. Date test plant list is being submitted to TAG-BCAW. 

2. Name of the researcher or petitioner submitting test plant list, (address, 

email address, telephone number, and fax number), affiliation and a contact 

point within North America (address, email address, telephone number, 

and fax number). 

3. Name of the target weed, including its order, family, genus, species, and 

common name(s). 

4. State if the weed is targeted for biological control the first time. 

5. If this is not the first time the weed is targeted, then include the previous 

petition number assigned by TAG-BCAW. 

6. If any proposed biological control agent(s) of weeds, then identify the 

agent(s). 

7. Location. 

5-3-2 TAG-BCAW Manual 10/2023-05 
Format for Test Plant Lists 

Introduction to the Test Plant List 

Include the following information in the Introduction to the Test Plant List 

section: 

Nature of the Problem 

Proposed Action 

Nature of the Problem 

Give a brief summary (one to two paragraphs) of the problems caused by the 

target weed. Items to consider follow: 

1. History of introduction and spread of the target weed. 

2. Weed’s present distribution in North America. 

3. Sectors affected and magnitude of program (e.g., agricultural, natural, 

rangeland). 

4. Consensus that the weed is suitable target for control. 

Proposed Action

Include the following statement: 

This host plant list is to notify TAG-BCAW of our intent to begin a 

biological control program for the control of [weed]. [Weed] has been 

declared a noxious weed in [list States] and is considered a target for 

biological control. Your comments on the accuracy, appropriateness, and 

thoroughness of this list is appreciated.” 

Target Weed Information 

Include the following in the Target Weed Information section: 

Taxonomy 

Description 

Distribution of the Target Weed 

Taxonomically Related Plants 

Distribution of Taxonomically Related Plants 

Life History 

Impacts 

Alternative Management Options 

Known Host Range of Proposed Biological Control Agent 

10/2023-05 TAG-BCAW Manual 5-3-3 
Format for Test Plant Lists 

Taxonomy 

Include the target weed taxonomy information, as follows: 

1. Full classification (including order, family, genus, species), synonymy, and 

common name. 

2. The taxonomist who identified the target weed, including name(s), 

organization(s), and location(s). 

3. Problems in identification or present taxonomy. 

4. Origin and locations of herbaria containing the voucher specimens used as 

representative of the population that occurs in the area where the researcher 

has conducted the studies and the date of deposit. 

Description 

Provide a general physical description of the target weed, complete enough so 

identification could be made by a person encountering the target weed in the 

field. 

Distribution of the Target Weed 

Describe the distribution of the target weed using maps, as appropriate. Include 

the following information: 

1. Native range (map). 

2. Areas of introduction throughout the world, pattern of movement, and 

apparent limits (map). 

3. Present distribution in North America (map). 

4. Range areas of potential spread in North America (map). 

5. Genetic variability. 

6. Habitats or ecosystems where this weed is found in North America. 

Taxonomically Related Plants 

Include the following: 

1. Identify the economically and environmentally important plants that are 

closely related to the target weed. These are crops, ornamentals, and native 

plants. 

2. Identify threatened and endangered species closely related to the target 

weed. 

3. If possible, identify how closely related economic, environmentally 

important species, and threatened and endangered species are to the target 

weed. 

5-3-4 TAG-BCAW Manual 10/2023-05 
Format for Test Plant Lists 

Distribution of Taxonomically Related Plants 

Describe the distribution and habitats in North America of the closely-related 

(taxonomically related) plants and identified under Taxonomically Related 

Plants). 

Life History 

Explain the life history and general biology of the target weed. Discuss the 

factors that are believed to contribute to the plant’s invasiveness. 

Impacts 

Indicate any and all impacts of the target weed. Use the following list as a 

guide and indicate the impacts (not all areas listed below are applicable to all 

weeds). 

1. Beneficial uses: honey bees, forage, ground cover, fruit, etc. 

2. Cultural, social and recreation uses: value as ornamentals. 

3. Threatened and endangered species. 

4. Economic losses, including direct control costs. 

5. Health: poisonous, allergens. 

6. Regulatory: noxious weed, restricts trade. 

7. Effects on native plant populations. 

8. Weed control on nontarget plants. 

9. Ecosystem functions and ecological relationships. 

10. Other impacts (e.g., aesthetic). 

Alternative Management Options 

Describe alternative options for managing the target weed and include the 

following: 

1. Historical options: what has been done before. 

2. Current options: biological, chemical, cultural. 

3. Potential options: new herbicides or biological control agents used or 

released in other countries. 

10/2023-05 TAG-BCAW Manual 5-3-5 
Format for Test Plant Lists 

Known Host Range of Proposed Biological Control Agent 

If known, then provide the following information about the proposed 

biological control agent: 

1. Name(s) and taxonomic classifications (order, family, genus, species). 

2. Literature records indicating other plants that have been attacked. 

3. Field collections and observations, including maps and data. 

4. Literature on host range of closely-related species to the proposed 

biological control agent. 

If the host range of the proposed biological control agent of weeds is unknown, 

then indicate “the unknown.” 

Test Plant List 

See ESA Section 7 Interagency Cooperation (50 CFR Part 402) Overview on 

page 6-2 for guidelines to comply and to expedite any review necessary 

because of protected species. Consult the U.S. Fish and Wildlife Service very 

early in the project. 

Include the following under the Test Plant List section: 

Categories of Test Plants 

Category 1: Genetic types of the target weed species (varieties, races, 

forms, genotypes, apomicts, etc.) found in North America and the 

native range. 

Category 2: Species in the same genus as the target weed, divided by 

subgenera (if applicable) 

Category 3: Species in other genera in the same family as the target 

weed, divided by subgenera (if applicable) 

Category 4: Threatened and endangered species in the same family as 

the target weed divided by subfamily, genus, and subgenus 

Category 5: Species in other families in the same order that have some 

phylogenetic, morphological, or biochemical similarities to the target 

weed 

Category 6: Species in other orders that have some morphological or 

biochemical similarities to the target weed 

Category 7: Any plant on which the proposed biological control agent 

or its close relatives have been previously found or recorded to feed 

and/or reproduce 

5-3-6 TAG-BCAW Manual 10/2023-05 
 

Format for Test Plant Lists 

Categories of Test Plants 

The usual strategy for developing a test plant list for evaluating biological 

control agents of weeds in North America is based on A. J. Wapshere (1974), A 

Strategy for Evaluating the Safety of Organisms for Biological Weed Control, 

published in Annals of Applied Biology. The strategy is based on the 

phylogenetic approach, where closely-related species are theorized to be at 

greater risk of attack than are distantly-related species. 

Category 1: Genetic types of the target weed species (varieties, races, forms, 

genotypes, apomicts, etc.) found in North America and the native range. 

Include the following information: 

Genetic variability of the target weed; 

Justification of genetic types selected for testing from those identified; 

Inferences about effects on untested types based on selected types (if any); 

If many types exist, then justification of the number selected for testing; 

References; and 

If references are not available, then provide an explanation. 

Category 2: Species in the same genus as the target weed, divided by subgenera (if 

applicable). 

Include the following information: 

Detailed information on what is known about the phylogenetic 

relationship of the target weed to other species in the same genus; 

Information on which species are most likely to be found in the same 

range and habitat as the target weed; 

Information on any economically, environmentally, and culturally 

sensitive important plant species of North America found in the genus; 

Justification of species selected for testing from those identified in the 

same genus as the target weed; 

Discussion of how the selected species may or may not enable the 

petitioner to make inferences about effects on untested species; 

If there are many species in the genus, then justification of the number 

selected for testing; 

References; and 

If references are not available, then provide an explanation. 

10/2023-05 TAG-BCAW Manual 5-3-7 
Format for Test Plant Lists 

Category 3: Species in other genera in the same family as the target weed, divided by 

subgenera (if applicable). 

Include the following information: 

Detailed information on what is known about the phylogenetic 

relationship of the target weed to other groups (i.e., subfamilies, genera, 

species in the same family); 

Information on which groups (i.e., subfamilies, genera, species) are most 

likely to be found in the same range and habitat as the target weed; 

Information on any economically, environmentally, and culturally 

sensitive important species found in the family in North America; 

Justification of the species selected for testing from those identified as 

Category 3; 

Discussion of how the selected species may or may not enable the 

petitioner to make inferences about effects on untested species; 

If there are many genera in the family, then justification of the number 

selected for testing; 

References; and 

If references are not available, then provide an explanation. 

Category 4: Threatened and endangered species in the same family as the target 

weed divided by subfamily, genus, and subgenus. 

Include the following information in a table format: 

All known species in the same family as the target weed that are listed as 

threatened or endangered species or candidates, including the full 

scientific name (order, family, subfamily, genus, subgenus, species), 

status, and range in North America (see references for Protected Species 

on page F-20); 

All species in the same genus as the target weed that are listed by the U.S. 

Fish and Wildlife Service as threatened or endangered or candidates 

(see Section 7 Consultations on page 6-1 and Protected Species on page 

F-20); 

All species within the same genus as the target weed that are identified as 

sensitive on designated lists, such as Natural Heritage Program lists, 

Canadian Province lists, or Mexican State lists 

(The Conservation Directory is a good resource to identify organizations 

that maintain such lists. See Protected Species on page F-20); 

Which groups (threatened or endangered species) are likely to be found in 

the same range and habitat as the target weed; 

Justification of the species selected for testing from those identified as 

Category 4 or select surrogates, since seeds/plants of threatened and 

5-3-8 TAG-BCAW Manual 10/2023-05 
Format for Test Plant Lists 

endangered species can be hard to obtain and may further threaten 

populations; 

Justification of the surrogates based on phylogenetic, morphological, 

and/or biochemical similarities; 

Discussion of how the selected species may or may not enable the 

petitioner to make inferences about effects on untested species; 

If many threatened and endangered species exist, then justify the number 

selected for testing; and 

References of threatened and endangered lists consulted. 

Category 5: Species in other families in the same order that have some phylogenetic, 

morphological, or biochemical similarities to the target weed. 

Include the following information: 

Outline of families in the same order as the target weed; 

Classification using Angiosperm Phylogeny Classification System and 

including any additional families listed; 

If using an alternate system of classification, then justification of its use; 

Which families in this order are most closely related to the target weed’s 

family according to phylogenetic studies; 

Discussion of any morphological or biochemical relationship the target 

weed or its family has with any group (i.e., family, genus, species) in this 

order; 

Which groups (i.e., family, genus, species) are likely to be found in the 

same range and habitat as the target weed; 

Any economically, environmentally, culturally sensitive, important 

species in these groups (i.e. family, genus, species) found in North 

America; 

Justification of the species selected for testing from those identified as 

being in Category 5; 

Discussion of how the selected species may or may not enable the 

petitioner to make inferences about effects on untested species; 

If there are many groups (i.e., species, genus, family), then an explanation 

of the number selected for testing; 

References; and 

If references are not available, then provide an explanation. 

10/2023-05 TAG-BCAW Manual 5-3-9 
Format for Test Plant Lists 

Category 6: Species in other orders that have some morphological or biochemical 

similarities to the target weed. 

Include the following information: 

Discussion of any morphological or biochemical relationship the target 

weed has with any group (i.e., family, genus, species) in other orders; 

Which groups (i.e., family, genus, species) are likely to be found in the 

same range and habitat as the target weed; 

Any economically, environmentally, and culturally sensitive, important 

plant species in these groups (i.e., family, genus, species) found in North 

America; 

Justification of the species selected for testing from those identified as 

being in Category 6; 

Discussion of how the selected species may or may not enable the 

petitioner to make inferences about effects on untested species; 

If there are many groups (i.e., family, genus, species), then explain the 

number selected for testing; 

References; and 

If references are not available, then provide an explanation. 

Category 7: Any plant on which the proposed biological control agent or its close 

relatives have been previously found or recorded to feed and/or reproduce. 

Include the following information: 

Details, including the full scientific name and range of any plant on which 

the proposed biological control agent or its close relatives (within the 

same genus) have been previously found or recorded to feed and/or 

reproduce; 

Proposal to test all species on which the proposed biological agent of 

weeds has been found or recorded to feed and/or reproduce; 

Species selected for testing from the plants on which any close relatives 

have been recorded to feed; 

Justification of the species selected from those identified; 

Discussion of how the selected species may or may not enable the 

petitioner to make inferences about effects on untested groups; and 

If many species have been fed/reproduced on by the agents’ close 

relatives, then provide an explanation of the number for testing. 

5-3-10 TAG-BCAW Manual 10/2023-05 
 

 

 

 

Format for Test Plant Lists 

Summary Table 

Summarize in a table format, all the species being considered for testing. 

Include pertinent literature references that are helpful in describing rationale. 

List the species in phylogenetic order (i.e., distantly- to closely-related to the 

target weed). 

NOTICE 

In actual host testing of proposed biological control agents of weeds, not all of these 

plants are expected to be used. Depending on the feeding behavior or life cycle of 

the agent, the researcher would select representative features similar to those on 

which the agent normally feeds. 

EXAMPLE If the agent’s larva overwinter in a large tap root, then annual plants or those 

with fibrous roots could be disregarded. 

Perspective of Risk 

Include the following under Perspective of Risk: 

1. Briefly discuss how the selected species should enable inferences to be 

made about risk of attack on untested species. 

2. Indicate the limits of allowable attack within the phylogenetic hierarchy of 

the test plant list, and why. 

3. Include pertinent literature references that are helpful in describing 

rationale. 

10/2023-05 TAG-BCAW Manual 5-3-11 
Strategy for Developing a Test Plant List 

Strategy for Developing a Test Plant List 

The following steps are only a suggested strategy for developing a test plant 

list. Follow this strategy along with the Angiosperm Phylogeny Plant 

Classification System and the references listed in Table 5-3-1 on page 5-3-13. 

1. Outline the families in the same order as the target weed using the 

Angiosperm Phylogeny Group classification. 

2. Examine the placement of the target weed family in the Angiosperm 

Phylogeny Group classification. 

3. If the Angiosperm Phylogeny Group places a new family in the order of the 

target weed, then consider that family when developing a list of Category 5 

plants. 

4. If only one of the systematists places a new family in the order of the target 

weed, then consider that family when developing a list of Category 6 

plants. Look for economically or environmentally important species in the 

new families that occur in the target areas. 

5. The references listed in Table 5-3-1 may be useful in developing a list of 

test plants for each category. See full References on page F-1. 

5-3-12 TAG-BCAW Manual 10/2023-05 
 

 

 

Strategy for Developing a Test Plant List 

Table 5-3-1 References for Developing a Test Plant List 

Helpful References Categories 

The Angiosperm Phylogeny Group Classification 5, 6 

Andersen Horticultural Library’s Sources List of Plants and Seeds. Issacson, R.T. (1993 or later edition) 1, 2 

Hortus Third, A Concise Dictionary of Plants Cultivated in the United States and Canada. Bailey, L.H. and 

Bailey, E.Z. (1976) 

1, 2, 3, 5 

A Synonymized Checklist of the Vascular Flora of the United States, Canada, and Greenland. Kartesz, 

J.T. (1994) 

1, 2, 3, 5 

Dictionary of Economic Plants. Uphof, J.C.Th. (1968) 2, 3, 5 

Families and Genera of Spermatophytes Recognized by the Agricultural Research Service. ARS Technical Bulletin 1796 3, 5 

Germplasm Resources Information Network (GRIN) database at https://npgsweb.ars-grin.gov/gringlobal/ 

taxon/taxonomyquery.aspx USDA Agriculture Research Service (ARS) 

1, 2, 3 

Gray’s Manual of Botany. Fernald, M.L. (1970) 2, 3, 5 

Manual of Cultivated Plants. Bailey, L.H (1951) 2, 3, 5 

Mabberley’s Plant Book. Mabberley, D.J. (2008) 2, 3, 5, 6 

North American floras that include the release areas 2, 3, 5, 6 

The PLANTS Database at http://plants.usda.gov/. USDA NCRS. National Plant Data Center, Baton 

Rouge, LA 70874-4490 USA 

2, 3 

U.S. Fish and Wildlife Services Endangered Species Program Site at http://www.fws.gov/endangered/. 

List of endangered and threatened species, including candidate species 

2, 3, 4 

10/2023-05 TAG-BCAW Manual 5-3-13 
Strategy for Developing a Test Plant List 

5-3-14 TAG-BCAW Manual 10/2023-05 
 

Format and Evaluation 

Test Plant List Evaluation 

Chapter 

5 

Contents 

Introduction 5-4-1 

Evaluation Guidelines for Test Plant Lists 5-4-1 

Questions or Concerns During Review or Evaluation 5-4-2 

Sending Test Plant Lists Out for Additional Comments 5-4-3 

Recording Comments 5-4-3 

Reviewer’s Overall Recommendation 5-4-3 

Target Weed Information 5-4-3 

Evaluation Checklist for Test Plant Lists 5-4-5 

Reviewer’s Recommendation Checklist for Test Host Plant Lists 5-4-17 

Introduction 

The Test Plant List Evaluation section of the Format and Evaluation chapter 

provides the evaluation guidelines and the evaluation checklist for 

TAG-BCAW members to use when evaluating a proposed test plant list. 

Petitioners may use the checklist to double-check their test plant lists prior to 

submitting to USDA-APHIS-PPQ. 

Evaluation Guidelines for Test Plant Lists 

When a test plant list is submitted by a petitioner or researcher, TAG-BCAW 

members must subject the test plant list to as critical a review as would be used 

for evaluating a petition. Starting a biological control program with the best 

possible test plant list will ultimately save valuable time, money, and patience 

for government and public supporters of biological control. 

The test plant list you will be reviewing may be either of the following: 

Test plant list for TAG-BCAW evaluation submitted early in the study 

when a researcher or petitioner is proposing a new weed for biological 

control, but prior to actually submitting the petition for biological control 

agent of weeds (TAG-BCAW may make recommendations of plants to be 

used in the testing process); or 

Test plant list (of plants actually used in the testing process) to TAGBCAW submitted for the first time along with the petition for biological 

control agent of weeds. 

10/2023-05 TAG-BCAW Manual 5-4-1 
Evaluation Guidelines for Test Plant Lists 

If the original test plant list is being submitted early in the study but prior to 

actually submitting the petition for biological control agent of weeds, then the 

TAG-BCAW reviewer will make recommendations on the target weed choice 

and comments on the proposed test plant list for host specificity testing. This 

provides the researcher or potential petitioner the opportunity to conduct 

additional research and field tests of test plants and to adjust the test plant list 

prior to submitting the actual petition for field release of biological control 

agent of weeds. 

If the original test plant list is being submitted for the first time along with the 

petition for field release of biological control agent, then the petitioner must 

give complete information on the target weed and the biological control agent. 

If the updated test plant list is being submitted along with the petition for 

biological control agent, then the petitioner must give complete information on 

the target weed and biological control agent and have made improvements to 

the list of plants that have actually been tested based on TAG-BCAW’s 

evaluation of the original test plant list. Thoroughly justifying additions to the 

test plant list is important. 

The evaluation guidelines provide a strategy for TAG-BCAW members to 

evaluate test plant lists to determine host specificity. The strategy is based on 

A. J. Wapshere (1974), A Strategy for Evaluating the Safety of Organisms for 

Biological Weed Control, published in Annals of Applied Biology. The strategy 

is based on the phylogenetic approach, where closely-related species are 

theorized to be at greater risk of attack than are distantly-related species. 

Questions or Concerns During Review or Evaluation 

If a TAG-BCAW member reviewing a test plant list has questions or concerns 

that only the petitioner or researcher could answer or resolve, then contact the 

petitioner or researcher directly. The TAG-BCAW member will notify the 

TAG-BCAW Chair about the question(s) and the petitioner’s or researcher’s 

answers, so the other TAG-BCAW reviewers can be kept informed (as they 

may have similar questions). 

5-4-2 TAG-BCAW Manual 10/2023-05 
Evaluation Guidelines for Test Plant Lists 

Sending Test Plant Lists Out for Additional Comments 

TAG-BCAW members reviewing test plant lists should formulate sending test 

plant lists out for additional comments as follows: 

1. Establish timelines for additional review of the test plant list, keeping in 

mind that the time frame for reviewing and evaluating petitions is 6 weeks. 

Allow time for any subject matter expert(s) to review and evaluate the 

petition, as well as time to synthesize comments and recommend action. 

2. Decide whether to send the entire test plant list or a portion of the test plant 

list out for comments. 

3. Prepare a request for additional comments cover letter with the following 

information: 

A. Specific guidance on which part of the test plant list you need the 

subject matter expert(s) (SME) to review. 

B. Your contact information in case the SMEs have questions or concerns. 

As a TAG-BCAW member, you should remain the individual who 

directly contacts the petitioner or researcher. 

C. Timeline of when you expect a reply from the SME(s). 

Recording Comments 

Each TAG-BCAW member reviewing a test plant list will use the TAG-BCAW 

Reviewer’s Comment Sheet for Test Host Plants Lists for Proposed Biological 

Control Agents of Weeds (see example on page page B-1-5), to record any 

comments. 

If you sent the test plant list for additional review(s), then list the names of the 

subject matter expert(s) in Block D, Comments/List of Additional Subject 

Matter Experts of the comment sheet (see page B-1-5). 

Reviewer’s Overall Recommendation 

After reviewing all sections of and completing the Evaluation Checklist for 

Test Plant Lists on page 5-4-5 and theReviewer’s Recommendation Checklist 

for Test Host Plant Lists on page 5-4-17, the TAG-BCAW reviewer will then 

use the information to develop an overall evaluation and recommendation and 

record on the page B-1-6. 

Target Weed Information 

To locate references about economic botany, protected species, host specificity, 

plant classification system, plant taxonomy and distribution, and previouslysubmitted petitions, see Table 5-4-1. 

10/2023-05 TAG-BCAW Manual 5-4-3 
 

 

 

 

Evaluation Guidelines for Test Plant Lists 

Table 5-4-1 Where to Find More Target Weed Information 

If you need to review basic information or 

research additional references about: And is for: Then: 

Economic Botany GO to Economic Botany on page F-1-15 

Protected Species GO to Protected Species on page F-1-20 

Host Specificity Arthropods GO to Host Specificity Testing of 

Arthropods on page 4-3-1 andTesting 

Methodology for Biological Control on 

page F-1-25 

Pathogens GO to Host Specificity Testing of 

Pathogens on page 4-4-1 and Testing 

Methodology for Biological Control on 

page F-1-25 

Plant Classification System GO to Plant Classification System on 

page E-1-1 

Plant Taxonomy and Distribution GO to Plant Taxonomy and Distribution 

on page F-1-16 

Submitted Petitions Current List GO to TAG-BCAW Web site 

Historical List GO to TAG-BCAW Web site 

5-4-4 TAG-BCAW Manual 10/2023-05 
Evaluation Checklist for Test Plant Lists 

Evaluation Checklist for Test Plant Lists 

Continue below and use the checklist in Table 5-4-2 to evaluate the test plant 

lists. 

Table 5-4-2 Evaluation Checklist for Test Plant Lists 

Test Plant List Section Is the following information included: Yes No 

Cover Page Date test plant list submitted to TAG-BCAW by 

the petitioner (see page 5-3-2) 

Name of the researcher or petitioner submitting 

test plant list, affiliation, and contact point in 

North America (address, email address, 

telephone number, fax number) 

Target weed (order, family, genus, species), 

common names 

First time this weed is targeted for biocontrol 

If this is not the first time this weed is targeted 

for biological control, then lists the previous 

petition number assigned by TAG-BCAW 

Proposed biological control agent(s) of weeds 

(if any) 

Location 

10/2023-05 TAG-BCAW Manual 5-4-5 
Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

Test Plant List Section Is the following information included: Yes No 

 

 

Introduction to the 

Test Plant List 

(see page 5-3-3) 

Nature of the 

Problem 

(see page 5-3-3) 

TAG-BCAW Reviewers: The introduction of the 

test plant list should provide a quick overview of 

the nature of the problem and the researcher’s 

proposed action. After reviewing, determine if 

you will need a subject matter expert within your 

Agency or organization to review the test plant 

list in order to formulate an informative 

recommendation from your Agency’s or 

organization’s perspective. 

If you need additional reviews, then follow the 

guidelines for Sending Test Plant Lists Out for 

Additional Comments on page 5-4-3. To locate 

more information about target weeds, see Target 

Weed Information on page 5-4-3 

Brief summary of the nature of the problem 

(History of introduction and spread of the target 

weed) 

Weed’s present distribution in North America 

Sectors affected and magnitude of program 

(e.g., agricultural, natural, rangeland) 

Consensus that the weed is suitable target for 

control 

Proposed Action Brief summary of researcher’s proposed action: 

(see page 5-3-3) This host plant list is to notify TAG-BCAW 

of our intent to begin a biological control 

program for the control of [weed]. [Weed] 

has been declared a noxious weed in [list 

States] and is considered a target for 

biological control. Your comments on the 

accuracy, appropriateness, and 

thoroughness of this list is appreciated 

5-4-6 TAG-BCAW Manual 10/2023-05 
Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

 

Target Weed 

Information 

(see page 5-3-3) 

Test plant list for TAG-BCAW evaluation was 

submitted early in the study when a researcher 

or petitioner is proposing a new weed for 

biological control, but prior to actually submitting 

the petition for biological control agent of weeds 

(TAG-BCAW may make recommendations of 

plants to be used in the testing process) 

Test plant list (of plants actually used in the 

testing process) to TAG-BCAW submitted for the 

first time along with the petition for biological 

control agent of weeds 

This weed has been previously targeted and 

there is either a previously-submitted petition or 

a previously-submitted test plant list 

If there is a previously submitted test plant list or 

petition, then the current discussion of weed and 

test plant information is compared with previous 

discussions 

Taxonomy 

(see page 5-3-4) 

Full classification (order, family, genus, species), 

synonymy, and common name 

Classification goes far enough to address any 

concerns 

There is evidence that the identification needs to 

go beyond species 

Qualified taxonomist (person’s name, 

organization(s), location(s) who identified the 

target weed 

Problem(s) exists with the identification or 

present taxonomy (if any) 

Origin locations of herbaria containing the 

voucher specimen(s) used as representative of 

the population occurring in the area where the 

researcher conducted the studies, and date of 

specimen deposit 

Test Plant List Section Is the following information included: Yes No 

10/2023-05 TAG-BCAW Manual 5-4-7 
Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

Test Plant List Section Is the following information included: Yes No 

Target Weed Description General physical description of the target weed 

Information is complete enough that identification could be (see page 5-3-4) made by a person encountering the weed in the (see page 5-3-3) field 

Distribution of the 

Target Weed 

(see page 5-3-4) 

Taxonomically 

Related Plants 

(see page 5-3-4) 

Distribution of 

Taxonomically 

Related Plants 

(see page 5-3-5) 

Life History 

(see page 5-3-5) 

TAG-BCAW Reviewers: This section should 

provide you with a sense of where the target 

weed is distributed and will potentially spread in 

North America 

Adequate description of the native range (map) 

Adequate description of the areas of introduction 

throughout the world, pattern of movement, and 

apparent limits (map) 

Adequate description of the present distribution 

in North America (map) 

Adequate description of the range areas of 

potential spread in North America (map) 

Adequate description of the genetic variability 

Adequate description of the habitats or 

ecosystems where the weed is found in North 

America 

Identification of economically and 

environmentally important plants that are closely 

related to the target weed 

Identification of threatened and endangered 

plants that are closely related to the target weed 

If possible, a description of how closely related 

economic, environmentally important species, 

and threatened and endangered species are to 

the target weed 

Adequate description of the distribution and 

habitats in North America of plants taxonomically 

related to the target weed and identified under 

Taxonomically Related Plants 

Explanation of the life history of the target weed 

Explanation of the general biology of the target 

weed 

Discussion of factors that contribute to the 

plant’s invasiveness 

5-4-8 TAG-BCAW Manual 10/2023-05 
Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

Test Plant List Section Is the following information included: Yes No 

Target Weed Impacts 

Information (see page 5-3-5) 

(see page 5-3-3) 

Information about the impacts made by target 

weeds are helpful in preparing a risk assessment 

and evaluating the risk associated with releasing 

the proposed biological control agent(s) of 

weeds. Use the following areas of impact as a 

guide. Not all areas will apply to all plants 

selected for testing 

Beneficial uses—honey bees, forage, ground 

cover, fruits, etc. 

Cultural, social and recreational uses—valued 

as an ornamental 

Threatened and endangered species 

Economic losses, including direct control costs 

Health—poisonous, allergens 

Regulatory—noxious weed, restricts trade 

Native plant communities 

Weed control on nontarget plants 

Ecosystem functions and ecological 

relationships 

Other impacts (e.g., aesthetic) 

10/2023-05 TAG-BCAW Manual 5-4-9 
Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

Test Plant List Section Is the following information included: Yes No 

Target Weed 

Information 

(continued) 

(see page 5-3-3) 

Alternative 

Management 

Options 

(see page 5-3-5) 

Known Host Range 

of Proposed 

Biological Control 

Agent 

(see page 5-3-6) 

Historical options—what has been done before 

Current options—biological, chemical, cultural 

Potential options—new herbicides, biological 

control agents used or released in other 

countries (researchers may not have information 

on new chemicals being developed) 

NOTICE 

The petitioner may not have addressed 

this topic since a test plant list is submitted 

early in the research. 

Name and taxonomic classification (order, 

family, genus, species) of the proposed 

biological control agent 

Literature records indicating other plants that 

have been attacked 

Field collections and observations, including 

maps and data 

Literature on host range of closely-related 

species to the proposed biological control agent 

of weeds 

If host range of the proposed biological control 

agent is unknown, then stated 

5-4-10 TAG-BCAW Manual 10/2023-05 
Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

Test Plant List Section Is the following information included: Yes No 

 

 

 

 

Test Plant List Review the test plant list to see if the following 

categories of plants are covered. The species (page 5-3-6) chosen for each category are representative 

species to be tested 

Category 1: Genetic Genetic variability of the target weed 

types of the target 

weed species Justification of the genetic types selected for (varieties, races, testing from those identified forms, genotypes, Discussion of how selected types may or may apomicts, etc.) found not enable the petitioner to make inferences in North America 

about effects on untested types (see page 5-3-7) Justification of the number selected for testing In 

the event that many types exist 

References 

If references are not included, then an 

explanation 

Category 2: Species in What is known about the phylogenetic 

the same genus as the relationship of the target weed to other species 

target weed, divided in the same genus 

by subgenera (if Which species are most likely to be found in the applicable) same range and habitat as the target weed 

(see page 5-3-7) Economically, environmentally, and culturally 

sensitive important plant species of North 

America found in the genus 

Justification of species selected for testing from 

those identified in the same genus as the target 

weed 

Discussion of how the selected species may or 

may not enable the petitioner to make 

inferences about effects on untested species 

If there are many species in the genus, then 

justification of the number selected for testing 

References 

If references are not included, then an 

explanation 

10/2023-05 TAG-BCAW Manual 5-4-11 
 

 

Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

Test Plant List Section Is the following information included: Yes No 

Test Plant List Category 3: Species in Details on what is known about the phylogenetic 

(page 5-3-6) other genera in the 

same family as the 

relationship of the target weed to other groups 

(i.e., subfamilies, genera, species) in the same 

target weed, divided family 

by subgenera (if 

applicable) Which groups (i.e., subfamilies, genera, species) 

are most likely to be found in the same range 

(see page 5-3-8) and habitat as the target weed 

Economically, environmentally, and culturally 

sensitive important species found in the family in 

North America 

Justification of the species selected for testing 

from those identified as Category 3 

Discussion of how the selected species may or 

may not enable the petitioner to make 

inferences about effects on untested species 

If there are many genera in the family, then the 

number selected for testing is justified 

References 

If references are not included, then an 

explanation 

5-4-12 TAG-BCAW Manual 10/2023-05 
 

 

 

 

 

Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

Test Plant List Section Is the following information included: Yes No 

Test Plant List 

(continued) 

(see page 5-3-6) 

Category 4: 

Threatened and 

endangered species in 

the same family as the 

target weed divided by 

subfamily, genus, and 

subgenus 

(see page 5-3-8) 

Category 4’s information is in a table format 

All known threatened or endangered species or 

candidates in the same family as the target 

weed, and includes the full scientific name 

(order, family, subfamily, genus, subgenus, and 

species), status, and range within North America 

(see references for Protected Species on page 

F-1-20) 

All species in the same genus as the target weed 

that are listed by the U.S. Fish and Wildlife 

Service as threatened or endangered or 

candidates (see Section 7 Consultations on 

page 6-1-1 and Protected Species on page 

F-1-20) 

All species within the same genus as the target 

weed that are identified as sensitive on 

designated lists, such as Natural Heritage 

Program lists, Canadian Province lists, or 

Mexican State lists 

(The Conservation Directory is a good resource 

to identify organizations that maintain such lists. 

See Protected Species on page F-1-20) 

Which groups (threatened or endangered 

species) are likely to be found in the same range 

and habitat as the target weed 

Justification of the species selected for testing 

from those identified as Category 4 or select 

surrogates (since seeds/plants of threatened 

and endangered species can be hard to obtain 

and may further threaten populations) 

Justification of the surrogates based on 

phylogenetic, morphological, and/or biochemical 

similarities 

Discussion of how the selected species may or 

may not enable the petitioner to make 

inferences about effects on untested species 

In the event that many threatened and 

endangered species exist, then a justification of 

the number selected for testing 

References of threatened and endangered lists 

consulted 

10/2023-05 TAG-BCAW Manual 5-4-13 
 

 

 

Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

Test Plant List Section Is the following information included: Yes No 

Test Plant List Category 5: Species in Outline of families in the same order as the 

(continued) 

(see page 5-3-6 

other families in the 

same order which 

have some 

phylogenetic, 

morphological, or 

biochemical 

similarities to the 

target weed 

Angiosperm Phylogeny Classification System 

used (see Plant Classification System on page 

E-1-1) and included any additional families listed 

If an alternate system of classification used, then 

a justification of the selection 

target weed Which families in this order are most closely 

(see page 5-3-9) related to the target weed’s family according to 

phylogenetic studies 

Discussion of any morphological or biochemical 

relationship the target weed or its family has with 

any group (i.e., family, genus, species) in this 

order 

Which groups (i.e., family, genus, species) are 

likely to be found in the same range and habitat 

as the target weed 

Any economically, environmentally, and 

culturally sensitive important species in these 

groups (i.e. family, genus, species) found in 

North America 

Justification of the species selected for testing 

from those identified as being in Category 5 

Discussion of how the selected species may or 

may not enable the petitioner to make 

inferences about effects on untested species 

If there are many groups (i.e., species, genus, 

family), then an explanation of the number 

selected for testing 

References 

If references are not included, then an 

explanation 

5-4-14 TAG-BCAW Manual 10/2023-05 
 

Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

Test Plant List Category 6: Species in Discussion of any morphological or biochemical 

other orders which relationship the target weed has with any group (continued) have some (i.e. family, genus, species) in other orders 

(see page 5-3-6) morphological or Which groups (i.e., family, genus, species) are biochemical likely to be found in the same range and habitat similarities to the as the target weed target weed Any economically, environmentally, culturally (see page 5-3-10) sensitive important species in these groups (i.e., 

family, genus, species) found in North America 

Justification of the species selected for testing 

from those identified as being in Category 6 

Discussion of how the selected species may or 

may not enable the petitioner to make 

inferences about effects on untested species 

If there are many groups (i.e., family, genus, 

species), then an explanation of the number 

selected for testing 

References 

If references are not included, then an 

explanation 

Category 7: Any plant Details, including the full scientific name and 

on which the biological range of any plant on which the biological control 

control agent or its agent or its close relatives (within the same 

close relatives (within genus) have been previously found or recorded 

the same genus) have to feed and/or reproduce 

been previously found Proposal to test all species on which the or recorded to feed proposed biological agent of weeds has been and/or reproduce found or recorded to feed and/or reproduce 

(see page 5-3-10) Species selected for testing from the plants on 

which any close relatives have been recorded to 

feed 

Justification of the species selected from those 

identified 

Discussion of how the selected species may or 

may not enable the petitioner to make 

inferences about effects on untested groups 

If many species have been fed/reproduced on by 

the agents’ close relatives, then explained the 

number for testing 

Test Plant List Section Is the following information included: Yes No 

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Evaluation Checklist for Test Plant Lists 

Table 5-4-2 Evaluation Checklist for Test Plant Lists (continued) 

Test Plant List Section Is the following information included: Yes No 

Summary Table 

(see page 5-3-11 

Table format summary of all the species 

recommended for testing in phylogenetic order 

(i.e., closely-to-distantly related to the target 

weed) 

Perspective of Risk 

(see page 5-3-11) 

Discussion of how the selected species should 

enable a TAG-BCAW Reviewer to make 

inferences about risk of attack on untested 

species 

Estimation of the limits of allowable attack within 

the phylogenetic hierarchy of the test plant list 

and explanation why 

References 

If references are not included, then an 

explanation 

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Reviewer’s Recommendation Checklist for Test Host Plant Lists 

Reviewer’s Recommendation Checklist for Test Host Plant Lists 

Use the results of the Evaluation Checklist for Test Plant Lists on page 5-4-5 

and complete Table 5-4-2. 

Read the information in Table 5-4-3 below, and follow the recommendation 

checklist. Use the TAG-BCAW Reviewer’s Comment Sheet for Test Host 

Plants Lists for Proposed Biological Control Agents of Weeds to record 

whether the information in the Test Plant List is complete and comprehensive 

or if information is lacking completeness. If information is lacking, then record 

your comment(s) about any concern(s) on the comments sheet, too.. 

Table 5-4-3 Checklist for Reviewer’s Completion of Test Host Plant Lists 

Reviewer’s Recommendation 

Review the completed evaluation Checklist for Test Plant Lists and 

comments made on the TAG-BCAW Reviewer’s Comment Sheet for Test 

Host Plants Lists for Biological Control Agents of Weeds, as well as those 

comments made by other subject matter experts 

Recommend the test plant list either be approved or be returned for 

revision and additions. Provide reasons for revision and additions 

Yes No 

Provide the name, affiliation, telephone, fax, and email numbers of the 

reviewer 

Include the names of other subject matter experts who provided 

comments 

Include your TAG-BCAW member identification number and date the 

Comment Sheet is submitted to TAG-BCAW Executive Secretary 

Send the completed TAG-BCAW Reviewer’s Comment Sheet for Test 

Host Plants Lists for Biological Control Agents of Weeds to the TAGBCAW Chair through the TAG-BCAW Executive Secretary at the following 

address: 

Mr. Gregg B. Goodman, 

TAG-BCAW Executive Secretary 

USDA-APHIS-PPQ 

4700 River Road, Unit 133, Office 4C-01.48 

Riverdale, MD 20737 

Email: gregg.b.goodman@aphis.usda.gov 

10/2023-05 TAG-BCAW Manual 5-4-17 
Reviewer’s Recommendation Checklist for Test Host Plant Lists 

5-4-18 TAG-BCAW Manual 10/2023-05 
ESA Compliance 

Section 7 Consultations 

Chapter 

6 

Contents 

Introduction 6-1-1 

Endangered Species Act (ESA) 6-1-1 

ESA Section 7 Interagency Cooperation (50 CFR Part 402) Overview 

6-1-2 

Technical Advisory Group for Biological Control Agents of Weeds (TAGBCAW) and Section 7 Consultations 6-1-6 

Introduction 

The Section 7 Consultations section of the ESA Compliance chapter provides 

an overview of Section 7 of the Endangered Species Act, U.S. Fish and 

Wildlife’s role with Section 7 in the review of biological control agents; and 

TAG-BCAW and Section 7 Consultations. 

Endangered Species Act (ESA) 

The Endangered Species Act (ESA) is one of the nation's most comprehensive 

and important environmental laws. Developing and implementing this 

landmark environmental legislation has placed the United States in the 

forefront of nations protecting imperiled species and habitat conservation. The 

ESA has served as a model for other nations to develop natural resource 

conservation programs and legislation. The core purpose of the ESA is to 

conserve endangered and threatened species and the ecosystems on which 

these species depend. 

Section 7 of the ESA addresses interagency cooperation. TAG-BCAW 

reviewers and petitioners are encouraged to read the ESA and its implementing 

regulations under Title 50 of the Code of Federal Regulations, especially the 

implementing regulations for Section 7 in 50 CFR Part 402. 

Continue to ESA Section 7 Interagency Cooperation (50 CFR Part 402) 

Overview. 

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ESA Compliance 

ESA Section 7 Interagency Cooperation (50 CFR Part 402) Overview 

ESA Section 7 Interagency Cooperation (50 CFR Part 402) Overview 

NOTICE 

This overview is not all encompassing concerning the intricacies of the ESA Section 

7 process, but provides a general blueprint to help petitioners facilitate necessary 

compliance and expedite ESA reviews. It is not intended to constitute, nor does it 

convey, legal advice. 

This overview covers what the Endangered Species Act (ESA) requires of 

Federal Agencies (in this case APHIS), and how petitioners can participate in 

the ESA Section 7 process. This includes the U.S. Fish and Wildlife Service’s 

(FWS) role on TAG-BCAW. FWS can assist in minimizing the risk to natural 

ecosystems associated with the use of biological control agents. 

Section 7(a)(1) requires all Federal Agencies, in consultation with and with the 

assistance of the Secretary of the Interior, to utilize their authorities to carry out 

programs for the conservation of endangered and threatened species. 

Section 7(a)(2, 4) requires all Federal Agencies, in consultation with and with 

the assistance of the Secretary of the Interior, to ensure that any action they 

fund, authorize, or carry out is not likely to jeopardize the continued existence 

of any listed species, or destroy or adversely modify designated critical 

habitat 1. 

The scope of Federal actions and authorizations that fall under Section 7 is 

broad and includes, but is not limited to, the granting of any Federal permit 

(such as an importation permit, a quarantine permit, and a release permit), or 

any other Federal-private nexus where the Federal government has a degree of 

discretionary authority. 

Accordingly, although Section 7 is specific to Federal actions, non-Federal 

actions (in this case, the release of biological control agents into the 

environment) are affected whenever a Federal action is required to authorize 

such an action. 

Consultation (Section 7(a)(3) is the process through which the FWS advises 

Federal Agencies on whether their actions may affect listed species or critical 

habitats. The National Marine Fisheries Service (NMFS) becomes involved in 

consultations when a class of listed marine species or certain anadromous fish 

are potentially affected. This consultation is mediated through the production 

1 Critical habitat refers to an area designated as critical habitat listed in 50 CFR Parts 17 or 226. 

6-1-2 TAG-BCAW Manual 10/2023-05 
 ESA Compliance 

ESA Section 7 Interagency Cooperation (50 CFR Part 402) Overview 

of a draft Biological Assessment (BA) which presents all the data in the 

petition that relates to host plant specificity and potential effects on threatened 

and endangered species (Section 7(c)). This BA is reviewed by FWS to 

determine if they concur with the decision by APHIS to move forward with 

permitting the release of the novel biological control agent. 

Where adverse effects are anticipated, FWS or NMFS determines whether the 

proposed Federal action under review is likely to jeopardize the continued 

existence of a listed species or destroy or adversely modify designated critical 

habitat. Federal actions that may affect species proposed for listing as 

threatened or endangered are reviewed in a conference review process (see 50 

CFR 402.10) that is similar to the consultation for listed species. 

The consultation process can be broken into two major parts: informal and 

formal. 

Informal Consultation 

Informal consultation is comprised of all communications between a Federal 

Agency (e.g., USDA-APHIS) and FWS and NMFS, that serve to determine 

whether the formal consultation is necessary. (For implementing regulations, 

see 50 CFR 402.13.) A table of ESA-listed species and critical habitats 

potentially occurring in the area directly or indirectly affected by the action can 

be obtained through the U.S. Fish & Wildlife Service Information for Planning 

and Consultation (IPaC) online tool or from the local FWS Office. 

If the proposed action may affect, but is not likely to adversely affect listed 

species or critical habitat and the FWS concurs with the determination, then 

formal consultation is not necessary. 

If listed species or habitats are present, then FWS can assist the Federal 

Agency by recommending project modifications that will avoid adverse 

impacts on species and their habitats. 

A Federal Agency may designate a non-Federal representative (e.g. a 

petitioner) to conduct informal consultation or to prepare a biological 

assessment (discussed in Biological Assessments and Effects Determination) 

by giving written notice to the Director of the FWS. If a permit or license 

applicant is involved and is not the designated non-Federal representative, then 

the applicant and the Federal Agency must agree on the choice of the nonFederal representative (50 CFR §402.08). 

10/2023-05 TAG-BCAW Manual 6-1-3 
 

ESA Compliance 

ESA Section 7 Interagency Cooperation (50 CFR Part 402) Overview 

Formal Consultation 

Should a Federal Agency determine that its anticipated actions may adversely 

affect a listed species or designated critical habitat, that Agency is required to 

initiate formal consultation (50 CFR §402.14) with the FWS and/or the NMFS. 

The Federal Agency must provide the FWS and/or the NMFS with a 

description of the proposed action and the area to be affected, and must 

include an analysis of the action's effect on listed species and designated 

critical habitats. (The Federal Agency may also review potential effects to 

proposed species and proposed critical habitat during a conference. See 50 

CFR § 402.10.) 

Section 7 and the consultation regulations (50 CFR §402.14(d)) require that the 

Federal Agency is responsible for providing the "best scientific and 

commercial data available or which can be obtained." The scope of what is 

included will likely be determined by the scope of the proposed project. 

Where a permit applicant or other non-Federal party is involved, the Federal 

Agency will frequently require that another party (e.g., petitioner) develop the 

required background information. 

For formal consultation, the FWS and/or the NMFS has up to 90 days to 

complete formal consultation, and up to an additional 45 days to complete a 

biological opinion. Extension of the formal consultation period can be made 

with an agreement between agencies, however, this cannot exceed 60 days 

without the consent of the applicant. A biological opinion states whether the 

activity is likely to jeopardize the continued existence of the listed species and/ 

or is likely to destroy or adversely modify designated critical habitats (50 CFR 

§ 402.02). During these 135 days, the FWS and/or the NMFS reviews all 

relevant data, evaluates the current status of the listed species or critical 

habitats, and formulates a biological opinion. 

To "jeopardize the continued existence of" means to engage in an action that is 

reasonably expected, directly or indirectly, to reduce appreciably the likelihood 

of survival and recovery of a listed species in the wild by reducing the 

reproduction, numbers, or distribution of that species (50 CFR § 402.02). 

To "destroy or adversely modify critical habitat" means a direct or indirect 

alteration that appreciably diminishes the value of critical habitat as a whole 

for the conservation of a listed species. (50 CFR § 402.02). 

In reaching these determinations, FWS and/or NMFS considers the status of 

the species, the environmental baseline (essentially, an evaluation of the past 

and present impacts within the action area prior to undertaking the proposed 

action), the direct and indirect effects of the action, and the cumulative effects 

of other anticipated actions that may affect the species. 

6-1-4 TAG-BCAW Manual 10/2023-05 
 ESA Compliance 

ESA Section 7 Interagency Cooperation (50 CFR Part 402) Overview 

Where a determination of jeopardy or adverse modification is made, FWS and/ 

or NMFS must develop reasonable and prudent alternatives that: 

Avoid jeopardy and/or adverse modification; 

Can be implemented consistent with the intended purpose of the action; 

Are within the Agency's authority; and 

Are economically and technologically feasible. 

These alternatives are developed in cooperation with the Federal Agency and 

the applicant (if any). 

Where an applicant for a Federal permit or other Federal authorization is 

involved, the Federal Agency is still the entity that initiates formal consultation 

and FWS still produces the biological opinion. However, the applicant can 

review drafts of the opinion and can require that consultation not be extended 

more than 60 days beyond the normal 90-day consultation period. 

The FWS and NMFS have a Consultation Handbook that provides in-depth 

information about ESA consultation. The FWS also provides an overview of 

the consultation process available at Consultations/Overview. 

10/2023-05 TAG-BCAW Manual 6-1-5 
 

ESA Compliance 

Technical Advisory Group for Biological Control Agents of Weeds (TAG-BCAW) and Section 7 Consultations 

Technical Advisory Group for Biological Control Agents of Weeds 

(TAG-BCAW) and Section 7 Consultations 

One of TAG-BCAW’s objectives is quite clear, “to provide an exchange of 

views, information, and advice for individuals who plan to ask various Federal 

and State regulatory agencies for permission to release these agents into the 

environment.” Although TAG-BCAW has no legal mandates or authorities 

pertaining to the issuance of permits, TAG-BCAW’s recommendations are 

strongly considered by decision makers. 

Through the proactive participation of the FWS on the TAG-BCAW, and 

through the development of effective and efficient ways for the regulatory 

agencies to comply with Section 7 of the ESA, the problems hindering the 

development and implementation of biological control programs will be 

minimized in the future. 

Part of the process for evaluating potential biological control agents of weeds 

is the development of a test plant list. Because the FWS TAG-BCAW member 

has input into the contents of the test plant list during review by the TAGBCAW, this helps ensure that the appropriate listed plants or surrogates are 

included in the host specificity tests. Through the reviews of the test plant list 

and the final petition for release, the FWS has the opportunity to raise any 

known concerns and to provide for the exchange of necessary information 

which facilitates communications throughout the review of the proposed 

biological control agents of weeds program. 

Petitioners should contact FWS regional offices as early in the evaluation 

process as possible, especially if the FWS TAG-BCAW member did not 

provide comments on the test plant list. (See U.S. Fish and Wildlife Service 

(FWS) Regional Offices on page D-1-1.) 

6-1-6 TAG-BCAW Manual 10/2023-05 
Chapter 

6 ESA Compliance 

Biological Assessments and Effects 

Determination 

Contents 

Introduction 6-2-1 

Biological Assessment (BA) 6-2-1 

Information That Is Included in a Biological Assessment 6-2-2 

Organization of Effects Determinations 6-2-7 

Introduction 

The Biological Assessments and Effects Determination section of the ESA 

Compliance chapter provides information about making effects determinations 

and guidelines for preparing a biological assessment or biological evaluation 

related to introducing biological control agents of weeds. This overview is not 

intended to constitute, nor does it convey, legal advice. 

Biological Assessment (BA) 

A biological assessment (BA) (sometimes referred to as a biological evaluation 

or BE) is a document prepared for compliance with the Endangered Species 

Act of 1973 (ESA) as amended. APHIS’ responsibility, as the project 

proponent, is to prepare the BA. The purpose of a BA or a document with 

equivalent information, is to evaluate the effects of a project on listed species, 

species proposed for listing, and/or critical habitat, as well as to determine the 

need for formal consultation or conference (for proposed species) with the U.S. 

Fish and Wildlife Service (FWS) and/or the National Marine Fisheries Service 

(NMFS). The BA should present a line of reasoning that explains the proposed 

biological control agent of weed, its host specificity and potential efficacy, and 

how effect determinations were made for each threatened or endangered 

species or critical habitat that may be effected by the agent. 

The permitted action for the release of a biological control agent of weeds will 

require both ESA and National Environmental Policy Act (NEPA) compliance. 

The BA should not be confused with the environmental assessment (EA) or 

the environmental impact statement (EIS), either of which may be required for 

NEPA compliance. The EA and EIS are designed to provide an analysis of 

multiple possible alternative actions on a variety of cultural, environmental, 

and social resources; and often use different definitions or standards, although 

10/2023-05 TAG-BCAW Manual 6-2-1 
 

ESA Compliance 

Biological Assessment (BA) 

impacts on listed species are included in the NEPA document. The BA, as 

described in detail below, is an analysis of the effects on listed and proposed 

species and their critical habitat. 

APHIS’ action which triggers the requirement to comply with the ESA, is the 

issuance of a permit authorizing release of a biological control agent of weeds 

into the environment. APHIS, as the Federal Agency, is responsible for 

preparing the BA and consulting with FWS and NFMS. 

The BA includes an analysis of potential effects to listed and proposed species 

and critical habitat in the entire action area. In order to prepare a BA, the 

petitioner will need to provide to APHIS, the items listed under Information 

That Is Included in a Biological Assessment. 

Information That Is Included in a Biological Assessment 

Information that is included in a Biological Assessment (BA) for release of a 

proposed biocontrol control agent of weeds (BCAW) is at the discretion of 

APHIS, but should include the following: 

1. Describe the action and the action area. 

A. Describe the proposed release. Include information about the proposed 

biological control agent of weed, including host specificity and efficacy 

information, and the target weed as well as plant relatives in the project 

area. 

B. Describe the action area. The action area is defined by regulation as “all 

areas to be affected directly or indirectly by the Federal action and not 

merely the immediate area involved in the action.” 

For proposed biological control agents of weeds, the project area may 

be the entire contiguous United States. For proposed release of a 

BCAW in Hawaii, the project area is usually considered to be the entire 

State. For release of a proposed BCAW in Guam, the action area is 

usually considered to be Guam and the Northern Mariana Islands. 

C. Describe current management of the target weed in the action area. 

D. Describe methods for release and post-release monitoring. 

E. Include documents, such as risk assessments, research proposals, 

NEPA documents, or published literature. The TAG-BCAW petition is 

generally the most useful information for preparing the BA. It is critical 

to discuss the host specificity of the proposed biological control agent 

of weed to the target weed and plants related to the target in the action 

area. 

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ESA Compliance

 Biological Assessment (BA) 

2. What threatened or endangered (listed or proposed) species or critical 

habitat occur in the action area? 

A request for a species list may be submitted to the FWS and/or NMFS; 

APHIS may develop the list. The U.S. Fish and Wildlife Service 

Environmental Conversation Online System, Threatened and Endangered 

Species web site provides species lists and information on proposed 

species, including species profiles and critical habitat. A list of species that 

may occur in a proposed BCAW release area can be generated in the U.S. 

Fish and Wildlife Service’s Information Planning and Consultation (IPAC 

System) online tool. 

It is critical for the researcher to conduct host specificity testing on listed 

plants (if they can be obtained) that are related to the target weed or 

appropriate surrogate species. Listed species such as animals or arthropods 

that may utilize the target weed (or other non-target plants that might be 

attacked by the biological control agent) as food or nectar sources, as 

cover, etc., will also be considered in the BA. Do not assume that because 

the listed plant does not occur in the same location as the target weed that 

there is no effect on a listed plant. 

3. What Federally-listed or proposed threatened or endangered species and 

critical habitat may be affected by the release of the BCAW, and what are 

those effects? 

APHIS considers the potential consequences of the release of the proposed 

BCAW on the listed species and critical habitat. 

Direct effects are those caused by the proposed BCAW and occur at the 

same time as its release. 

EXAMPLE A direct consequence could include feeding of the proposed BCAW 

on a listed plant which causes a decrease in size or reproduction of 

the plant. 

A direct consequence could be a proposed BCAW that is ingested by 

and is toxic to a listed animal. 

Indirect consequences are caused by the proposed BCAW and occur later 

in time, but are still reasonably certain to occur. 

EXAMPLE An indirect consequence is feeding of the proposed BCAW on a nonlisted plant species that provides breeding habitat, food, or shelter for 

a listed plant. 

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ESA Compliance 

Biological Assessment (BA) 

Direct or indirect consequences include any actions that could cause take 

(as defined by the ESA) to harass, harm, pursue, hunt, shoot, wound, kill, 

trap, capture, or collect or attempt to engage in any such conduct of even 

one individual of a listed species. 

Cumulative effects are those effects of future State or private actions, not 

involving Federal actions, that are reasonably certain to occur within the 

target area. 

It is important to consider whether the target weed is a primary physical or 

biological feature (sometimes referred to as primary constituent elements) 

of designated or proposed critical habitat for a listed species or whether the 

proposed BCAW could affect a physical or biological feature of the critical 

habitat. Physical and biological features of those that are essential to the 

conservation of the species. A BCAW may affect a physical or biological 

feature that could result in adverse modification of proposed or designed 

critical habitat and must be considered. 

Sources of information about listed species and critical habitat can be 

found at the U.S. Fish and Wildlife Service Environmental Conversation 

Online System, Threatened and Endangered Species web site. Species 

profiles include Federal Register Notices, Recovery Plans, 5-Year Status 

Reviews, links to NatureServe, Integrated Taxonomic Information System 

(ITIS), and other useful information. Published literature, FWS and/or 

NMFS and other species experts can also provide information about 

connections among listed species and target weeds. 

Under the ESA, effect determinations are made by APHIS for the proposed 

release of the BCAW on proposed and listed species and designated and 

proposed critical habitat. 

A. No effect. If APHIS determines that the proposed biological control 

agent of weed (BCAW) will have no effect, whether negative or 

positive, on any listed species or critical habitat, then no consultation 

by the FWS and/or NMFS is required and no action is necessary by the 

FWS and NFMS. A no effect determination is not appropriate if there 

is a small effect (e.g., an effect on a simple individual), a beneficial 

effect on listed species, or even if an effect is unlikely to occur. 

Even though consultation is not required for a no effect determination, 

a record of the determination should be maintained by APHIS for the 

administrative record and may be included in the NEPA 

documentation. 

B. May effect, not likely to adversely affect. APHIS makes this 

determination if the effect(s) of the proposed release of the biocontrol 

agent of weed (BCAW) on listed species or designated critical habitat is 

6-2-4 TAG-BCAW Manual 10/2023-05 
 

 

ESA Compliance

 Biological Assessment (BA) 

discountable, insignificant, or completely beneficial. Insignificant 

effects relate to the size of the impact and must never reach the scale 

where take occurs. Discountable effects are those that are extremely 

unlikely to occur. Beneficial effects are positive effects without any 

adverse effects to species. 

A may effect, not likely to adversely affect determination requires 

APHIS to seek concurrence from the FWS and NMFS. 

If the FWS and NMFS agree with the determination, then they will 

send a concurrence letter to APHIS and the informal consultation is 

completed. If the FWS and NMFS do not concur with the APHIS 

finding, then the FWS and NMFS provide a written response and 

formal consultation is required. 

C. May affect, likely to adversely affect. This determination is made if the 

effect of the proposed BCAW on listed species or designated critical 

habitat is not discountable, insignificant, or completely beneficial. This 

determination requires APHIS to initiate the formal consultation 

process with the FWS and/or NMFS. The formal consultation process 

determines whether the proposed action is likely to jeopardize the 

continued existence of the listed species (jeopardy) or destroy or 

adversely modify critical habitat. See 50 CFR 402.14(c)(i-vi). 

Briefly, the formal consultation is as follows: 

a. APHIS submits a biological assessment (BA), including a 

description of the proposed action, area affected by the action, 

effects of the action on listed species and proposed species and 

critical habitat, and relevant reports, studies, or information about 

the action, listed species, and critical habitat. 

b. FWS and/or NMFS then prepare a biological opinion that 

documents their opinion as to whether the proposed action is likely 

to jeopardize the continued existence of the listed species, or result 

in the destruction or adverse modification of critical habitat. 

c. If FWS or NMFS make a jeopardy determination, then APHIS 

would be provided with reasonable and prudent alternative actions 

that would avoid jeopardy. However, for release of a BCAW there is 

no possible reasonable and prudent alternative action, and the 

BCAW release proposal would be withdrawn. 

d. If incidental take 1 is reasonably likely to occur, then biological 

opinions provide an exemption for the incidental take of listed 

species through the issuance of an incidental take statement while 

specifying the extent of take allowed; the reasonable and prudent 

1 Take that is incidental to, and not for the purpose of, the carrying out of an otherwise lawful activity. 

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ESA Compliance 

Biological Assessment (BA) 

measures necessary to minimize impacts from Federal action; and 

the terms and conditions with which the action Agency must 

comply. 

The formal consultation process takes a minimum of 135 days. 

Effect determinations include a thorough analysis of effects using the 

best available science with a well-supported conclusion. Assume that 

the FWS and/or NMFS biologist is unfamiliar with the project. Fully 

explain the impact the project may have on listed species. The FWS or 

NMFS may ask APHIS to revisit its decision and provide more data for 

the conclusion if it is not adequately supported by biological 

information. If this request occurs, then the statutory deadlines for 

formal consultation have not begun. 

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ESA Compliance

 Biological Assessment (BA) 

Organization of Effects Determinations 

Providing the effects determination in a table followed by a narrative summary 

paragraph is recommended. An example of a may affect, not likely to 

adversely affect (NLAA) is provided. When there is a no effect determination 

for a species, the information justifying that determination may be included in 

the B.A. 

The example in Table 6-2-1 documents listed species that occur in the action 

area and the effects analysis. The example in Table 6-2-2 documents 

conservation measures. The information in the tables below are hypothetical to 

illustrate data needs and analysis details. 

Table 6-2-1 Effects Analysis and Agency Determination 

Common Name Scientific Name Listing 

Status 

Critical 

Habitat 

States of 

Occurrence 

Impact/Effect to 

Breeding, 

Feeding, 

Sheltering, 

Migration, 

Nutrition, and 

Life Stage 

Determination 

Cuckoo, yellowbilled Coccyzus 

americanus 

T N AZ, CA, CO, 

MT, NV, NM, 

B=Yes 

F=No 

May affect, likely 

to be a beneficial 

(Western US DPS) OR, TX, UT, 

WA, WY 

S=No 

M=No 

effect on species 

N=No 

L=All 

Vireo, blackcapped Vireo atricapilla E N OK, TX B=No 

F=No 

S=No 

M=No 

N=No 

No effect 

The species will 

not interact with 

[BCAW] 

Vireo, least Bell’s Vireo bellii 

pusilus 

E Y CA B=Yes 

F=No 

S=No 

M=No 

May affect, not 

likely to 

adversely affect 

N=No 

L=All 

Orcutt grass, Orcuttia E N CA SEE Table 6-2-2 May affect, not 

California californica likely to 

adversely affect 

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Biological Assessment (BA) 

Table 6-2-2 Conservation Measures for Species Identified in Table 6-2-1 

Common Name 

Impact/Effect to 

Breeding, Feeding, 

Sheltering, Migration, 

Nutrition, and Life 

Stage 

Determination Impact/Effects Conservation 

Measure 

Cuckoo, yellow- B=Yes May affect, likely Nesting of the western yellow- None. Removal 

billed L=All to be a beneficial billed cuckoo has not been of Arundo donax 

(Western US 

DPS) 

effect on species documented in riparian stands 

dominated by the target weed. 

The target weed reduces the 

quality of yellow-billed cuckoo 

habitat. Removal of the target 

weed would be beneficial 

may benefit this 

species and its 

proposed critical 

habitat 

Vireo, least B=Yes May affect, not Target weed used by the vireo None 

Bell’s L=All likely to 

adversely affect 

for nesting. However, the target 

weed is rarely used. Reports 

indicate that less than 1% of 

nests occur in the target weed 

[Reference} 

Orcutt grass, May affect, not [BCAW] could feed on this Monitor for 

California likely to 

adversely affect 

plant, affecting its survival and 

reproduction. This plant occurs 

in the subfamily as the target 

weed. In host specificity testing, 

there was no development on 

species belonging to this 

subfamily. In addition [BCAW] 

would be unable to survive on 

California orcutt grass because 

part of the plant’s life cycle 

occurs in vernal pools. Orcuttia 

plants grow underwater for 3 

months or more and have 

evolved specific adaptations for 

aquatic growth. Finally this 

grass species is an annual and 

could not support the life cycle 

of [BCAW] 

non-target 

impacts at initial 

release sites. If 

non-target 

impacts are 

observed, then 

report them to 

the FWS and/or 

NMFS 

6-2-8 TAG-BCAW Manual 10/2023-05 
Appendix 

A TAG-BCAW Membership 

Directory 

Contents 

Introduction A-1-1 

TAG-BCAW Membership Directory A-1-1 

Introduction 

The TAG-BCAW Membership appendix provides a list of TAG-BCAW 

members with their addresses and phone numbers. 

TAG-BCAW Membership Directory 

Table A-1-1 TAG-BCAW Membership Directory 

TAG-BCAW Members Phone Number and Email Address 

Dr. Sharlene E. Sing, TAG-BCAW Chair Phone: 406-312-9052 

USDA-Forest Service Email: sharlene.sing@usda.gov Rocky Mountain Research Station 

Bozeman Forestry Sciences Laboratory 

1648 S. 7th Avenue, MSU Campus 

Bozeman, MT 59717-2780 

Mr. Gregg B. Goodman, TAG-BCAW Executive Secretary Phone: 301-851-2074 

USDA-APHIS-PPQ Email: gregg.b.goodman@usda.gov 4700 River Road, Unit 133 

Riverdale, MD 20737 

Mr. Lewis John Cook Phone: 406-247-7946 

USDI-Bureau of Indian Affairs Email: lewis.cook@bia.gov Rocky Mountain Regional Office 

316 North 26th Street 

Billings, MT 59101 

Mr. Seth Flanigan Phone: 208-373-4094 

Lead Natural Resource Specialist - Invasive Species Cell: 208-519-072 Division of Forestry, Rangeland, and Vegetation Resources (HQ-220) 

USDI-Bureau of Land Management Email: sflanigan@blm.gov 

1387 S. Vinnell Way 

Boise, ID 83709 

Dr. John Goolsby Phone: 956-373-3223 

USDA-Agriculture Research Service, Plains Area Email: john.goolsby@usda.gov 22675 N. Moorefield Road 

Moore Airbase, Building 6419 

Edinburg, TX 78541 

10/2023-05 TAG-BCAW Manual A-1-1 
 

TAG-BCAW Membership 

TAG-BCAW Membership Directory 

Table A-1-1 TAG-BCAW Membership Directory (continued) 

TAG-BCAW Members Phone Number and Email Address 

Mr. Nathan Harms Phone: 601-634-2976 

U.S. Army Corps of Engineers Email: nathan.e.harms@usace.army.mil 3909 Halls Ferry Road 

Vicksburg, MS 39180-0631 

Ms. Terri Hogan Phone: 970-267-7306 

Invasive Plant Program Manager Email: terri_hogan@nps.gov USDI-National Park Service 

Landscape Restoration & Adaptation 

Biological Resources Division 

Natural Resource Stewardship and Science 

1201 Oakridge Dr., Suite 200 

Fort Collins, CO 80525 

Erica Kistner-Thomas, Ph.D. Phone: 816-894-9283 

National Program Leader 

USDA-National Institute of Food and Agriculture Email: erica.kistnerthomas@usda.gov 

Institute of Food Production and Sustainability 

Kansas City, MO 

Dr. Peter Mason Phone: 613-759-1908 

Research Centre Email: peter.mason@canada.ca Agriculture and Agri-Food Canada 

K.W. Neathy Bldg. 

960 Carling Avenue 

Ottawa, ON, Canada KIAOC6 

Mr. Joseph Milan Phone: 208.384.3487 

Biological Control Specialist Email: jmilan@blm.gov USDI-Bureau of Land Management 

3948 Development Avenue 

Boise, ID 83705 

Mr. Ian Pearse Phone: 970-226-9145 

USGS-Fort Collins Science Center Email: ipearse@usgs.gov 2150 Centre Ave. #C 

Ft. Collins, CO 80526 

Mr. James Pieper Phone: 970-267-2144 

NPS Integrated Pest Management (IPM) Coordinator Email: james_pieper@nps.gov USDI-National Park Service 

Biological Resources Division 

Natural Resource Stewardship and Science 

1201 Oakridge Dr., Suite 200 

Fort Collins, CO 80525 

Eric Rohrig, Ph.D. Phone: 352-395-4744 

National Plant Board Representative Email: eric.rohrig@fdacs.gov Bureau Chief - Methods Development & Biological Control 

Division of Plant Industry 

Florida Department of Agriculture and Consumer Services 

1911 SW 34th St. 

Gainesville, FL 32608 

A-1-2 TAG-BCAW Manual 10/2023-05 
 

 

TAG-BCAW Membership 

TAG-BCAW Membership Directory 

Table A-1-1 TAG-BCAW Membership Directory (continued) 

TAG-BCAW Members Phone Number and Email Address 

Jolene Trujillo 

National IPM Coordinator 

USDI-Fish and Wildlife Service 

National Wildlife Refuge System 

U.S. Fish and Wildlife Service 

7333 Jefferson Ave. Suite 375 

Lakewood, CO 80235 

Phone: 703-859-1626 

Email: jolene_trujillo@fws.gov 

Mr. Jose Torres 

Subdirector de Diagnostico Fitosanitario 

SADER SENASICA-DGSV 

Carretera Federal Mexico-Pachuca, Km 37.5. 

C.P. 55740 Tecamac, Estada de Mexico 

Mexico 55740 

Phone: (+52) (55) 5905 1000 ext.51402 

Email: jose.torres@senasica.gob.mx 

Heidi McMaster 

Acting Invasive Species/IPM Program Coordinator 

USDI-Bureau of Reclamation 

1150 N. Curtis Rd. 

Boise, ID 83706 

Phone: 208-860-9649 

Email: hmcmaster@usbr.gov 

Dr. Sarah Ward 

Weed Science Society of America 

12110 N. Pecos St. 

Westminster, CO 80234 

Phone: 406-223-2899 

Email: sarah.ward@colostate.edu 

Ms. Tara Holtz, Acting 

Director of Domestic and Emergency Scientific Support 

USDA-APHIS-PPQ Science and Technology 

910 Main Campus Drive, Suite 500 

Raleigh, NC 27606 

Phone: 919-855-7423 

Cell: 919-270-9934 

Email: tara.m.holtz@usda.gov 

Dr. Patrick Moran 

USDA-Agricultural Research Service 

USDA-ARS WRRC ISPH 

800 Buchanan St. 

Albany, CA 94710 

Phone: 510-559-6393 

Email: patrick.moran@usda.gov 

Vacant 

EPA-Office of Pesticide Programs 

10/2023-05 TAG-BCAW Manual A-1-3 
TAG-BCAW Membership 

TAG-BCAW Membership Directory 

A-1-4 TAG-BCAW Manual 10/2023-05 
Forms Appendix 

B 

Contents 

Introduction B-1-1 

TAG-BCAW Reviewer’s Comment Sheet - Petition for Field Release of 

Proposed Biological Control Agents of Weeds B-1-2 

Purpose B-1-4 

Instructions B-1-4 

Distribution B-1-4 

TAG-BCAW Reviewer’s Comment Sheet for Test Host Plants Lists for 

Proposed Biological Control Agents of Weeds B-1-5 

Purpose B-1-7 

Instructions B-1-7 

Distribution B-1-7 

Instructions for Completing an Application for an APHIS Permit B-1-8 

Applying for an APHIS Permit B-1-8 

PPQ Form 526, Application to Move Live Plant Pests or Noxious Weeds 

B-1-9 

Purpose B-1-10 

Distribution B-1-10 

PPQ Form 599, Import Label for Living Regulated Organisms (Red and 

White) B-1-11 

Purpose B-1-12 

Distribution B-1-12 

Introduction 

The Forms appendix contains examples of comment sheets and forms that are 

used for evaluating petitions, evaluating test plant lists, or applying for permits 

for the biological control of weeds. 

10/2023-05 TAG-BCAW Manual B-1-1 
 

 

 

 

 

___________________________________________________________________________________________________ 

Forms 

TAG-BCAW Reviewer’s Comment Sheet - Petition for Field Release of Proposed Biological Control Agents of Weeds 

TAG-BCAW Reviewer’s Comment Sheet - Petition for Field Release 

of Proposed Biological Control Agents of Weeds 

Technical Advisory Group (TAG-W) Reviewer's Comment Sheet

for Field Release for Biological Control Agents of Weeds 

Section 1: To be completed by the TAG Executive Secretary Return Form to: 

Gregg Goodman, Executive Secretary 

Designation Number: Date Request Received: USDA, APHIS, PPQ 

4700 River Rd, Unit 133 

Date Sent to Reviewers: Review Due Date: Office 4C-01.48 

Riverdale, MD 20737-1236 

Due Date Revised: Fax (301) 734-5269 

Email: Gregg.B.Goodman@aphis.usda.gov 

Biological Control Agent(s): 

. 

Target Weed: 

Petitioner’s Name and Affiliation: 

Please rate your review with one of the following categories: 

A = Acceptable CM = Concerns Met 

UA = Unacceptable CNM = Concerns Not Met NE = Not Evaluated 

Section 2: To be completed by the TAG Reviewers (if needed, use additional sheets). Please change the circle to an “X” to 

acknowledge your choice. 

A. Accuracy, Completeness, and Comprehensiveness: 

A UA NE 

Target Weed 

Information Comments: _ 

O O O 

Biological Control Agent O O O 

Information Comments: _ 

Experimental Methodology O O O 

& Analysis Comments: _ 

Test Plant O O O 

Comments: __ 

Results & Discussion O O O 

Comments: __ 

Potential Environmental O O O 

Impact(s) Comments: __ 

Petitioner’s Conclusion O O O 

Comments: __ 

Figure B-1-1 Technical Advisory Group (TAG-BCAW) Reviewer’s Comment Sheet - Petition for Field 

Release of Biological Control Agents of Weeds (front) 

B-1-2 TAG-BCAW Manual 10/2023-05 
 

 

Forms 

TAG-BCAW Reviewer’s Comment Sheet - Petition for Field Release of Proposed Biological Control Agents of Weeds 

Please rate your review using one of the categories. 

B. Thoroughness of Addressing 

Agency Concerns Comments: __ 

CM 

O 

CNM 

O 

NE 

O 

C. Recommendation of Your 

Agency Comments: ___ 

D. Comments/list of 

Additional specialists’: ___ 

Please change the circle to an “X” to acknowledge your choice. 

Recommend without reservations 

Recommend with reservations 

(Please make specific comments) 

Not recommended 

O 

O 

O 

TAG #: ___________________________ 

Date: _____________________________ 

Thank you for taking the time to review this petition and document your recommendations. 

Figure B-1-2 Technical Advisory Group (TAG-BCAW) Reviewer’s Comment Sheet - Petition for Field 

Release of Biological Control Agents of Weeds (back) 

10/2023-05 TAG-BCAW Manual B-1-3 
Forms 

TAG-BCAW Reviewer’s Comment Sheet - Petition for Field Release of Proposed Biological Control Agents of Weeds 

Purpose 

The Technical Advisory Group TAG-BCAW Reviewer’s Comment Sheet - 

Petition for Field Release of Proposed Biological Control Agents of Weeds is 

used by TAG-BCAW reviewers to comment, evaluate, and recommend action 

for petitions for field release of biological control agents of weeds. 

Instructions 

The TAG-BCAW comment sheets are used along with the Evaluation 

Checklist — Petitions for Field Release of Biological Control Agents of Weeds 

on page 5-5 and Evaluation Checklist for Test Plant Lists on page 5-5. 

Distribution 

The TAG-BCAW Executive Secretary distributes a fillable pdf of the TAGBCAW Reviewer’s Comment Sheet - Petition for Field Release of Proposed 

Biological Control Agents of Weeds to TAG-BCAW members. 

Mr. Gregg B. Goodman 

TAG-BCAW Executive Secretary 

4700 River Road, Unit 133, 4D-01.42 

Riverdale, MD 20737 

E-mail: gregg.b.goodman@aphis.usda.gov 

FAX: 301-851-2074 

TAG-BCAW reviewers return the completed TAG-BCAW Reviewer’s 

Comment Sheet - Petition for Field Release of Proposed Biological Control 

Agents of Weeds to the TAG-BCAW Executive Secretary. The TAG-BCAW 

Executive Secretary will log in and file the recommendations, then forward to 

the TAG-BCAW Chair. 

B-1-4 TAG-BCAW Manual 10/2023-05 
 

 

 

 

 

___________________________________________________________________________________________________ 

_________________________________________________________________________________________________ 

_________________________________________________________________________________________________ 

_________________________________________________________________________________________________ 

________________________________________________________________________________________________ 

_________________________________________________________________________________________________ 

Forms 

TAG-BCAW Reviewer’s Comment Sheet for Test Host Plants Lists for Proposed Biological Control Agents of Weeds 

TAG-BCAW Reviewer’s Comment Sheet for Test Host Plants Lists for 

Proposed Biological Control Agents of Weeds 

Technical Advisory Group (TAG-W) Reviewer's Comment Sheet 

for Test Host Plants Lists for Biological Control Agents of Weeds 

Section 1: To be completed by the TAG Executive Secretary Return Form to: 

Gregg Goodman, Executive Secretary 

Designation Number: Date Request Received: USDA, APHIS, PPQ 

4700 River Rd, Unit 133 

Date Sent to Reviewers: Review Due Date: Office 4C-01.48 

Riverdale, MD 20737-1236 

Due Date Revised: Fax (301) 734-5269 

Email: Gregg.B.Goodman@aphis.usda.gov 

Biological Control Agent(s): 

Target Weed: 

Petitioner’s Name and Affiliation: 

Please rate your review with one of the following categories: 

A = Acceptable CN = Concerns Met 

UA = Unacceptable CNM = Concerns Not Met NE = Not Evaluated 

Section 2: To be completed by the TAG Reviewers (if needed, use additional sheets). Please change the circle to an “X” to 

acknowledge your choice. 

A. Accuracy, Completeness, and Comprehensiveness: 

A UA NE 

Target Weed O O O 

Information Comments: 

Test Plant List O O O 

Comments: 

Summary O O O 

Comments: 

Perspective of O O O 

Risk Comments: 

Please rate your review using one of the categories. 

CN CNM NE 

B. Thoroughness of Addressing O O O 

Agency Concerns Comments: 

C. Recommendation of Your 

Agency Comments: 

Figure B-1-3 TAG-BCAW Reviewer’s Comment Sheet for Test Host Plant Lists for Proposed Biological 

Control Agents of Weeds (front) 

10/2023-05 TAG-BCAW Manual B-1-5 
 

_________________________________________________________________________________________________ 

Forms 

TAG-BCAW Reviewer’s Comment Sheet for Test Host Plants Lists for Proposed Biological Control Agents of Weeds 

D. Comments/list of 

Additional specialists’: 

Please change the circle to an “X” to acknowledge your choice. 

Recommend without reservations O 

Recommend with reservations O 

(Please make specific comments) 

Not recommended O 

TAG #: __________________________________ 

Thank you for taking the time to review this petition and document your recommendations. 

Figure B-1-4 TAG-BCAW Reviewer’s Comment Sheet for Test Host Plant Lists for Biological Control 

Agents of Weeds (back) 

B-1-6 TAG-BCAW Manual 10/2023-05 
Forms 

TAG-BCAW Reviewer’s Comment Sheet for Test Host Plants Lists for Proposed Biological Control Agents of Weeds 

Purpose 

The TAG-BCAW Reviewer’s Comment Sheet for Test Host Plants Lists for 

Proposed Biological Control Agents of Weeds on page B-5 is used for TAGBCAW members to comment, evaluate, and recommend action about test host 

plant lists. 

Instructions 

The TAG-BCAW Reviewer’s Comment Sheet for Test Host Plants Lists for 

Proposed Biological Control Agents of Weeds is used along with the 

Evaluation Guidelines for Test Plant Lists on page 5-1 and Evaluation 

Checklist for Test Plant Lists on page 5-5. 

Distribution 

The TAG-BCAW Executive Secretary distributes a fillable pdf of the TAGBCAW Reviewer’s Comment Sheet for Test Host Plants Lists for Proposed 

Biological Control Agents of Weeds to TAG-BCAW reviewers. 

The TAG-BCAW reviewers return their completed TAG-BCAW Reviewer’s 

Comment Sheet for Test Host Plants Lists for Proposed Biological Control 

Agents of Weeds to the TAG-BCAW Executive Secretary using either of the 

following: 

Mr. Gregg B. Goodman, TAG-BCAW Executive Secretary 

USDA-APHIS-PPQ 

4700 River Road, Unit 133, 4C-01.48 

Riverdale, MD 20737 

Email: gregg.b.goodman@aphis.usda.gov 

The TAG-BCAW Executive Secretary then logs and files the comments, and 

sends the TAG-BCAW reviewers’ comment sheets to the TAG-BCAW Chair. 

10/2023-05 TAG-BCAW Manual B-1-7 
Forms 

Instructions for Completing an Application for an APHIS Permit 

Instructions for Completing an Application for an APHIS Permit 

As part of the U.S. Department of Agriculture’s (USDA) overall eGovernment 

initiative to transform and enhance delivery of its programs, services, and 

information, the Animal and Plant Health Inspection Service (APHIS) 

launched its electronic permitting system (ePermits). ePermits is a web-based 

tool that gives customers the ability to apply for a permit, check the status, and 

view the application online. All PPQ permits are processed through the 

ePermits system, however, there are two ways to apply for an APHIS permit: 

on-line or on paper. 

Applying for an APHIS Permit 

Guidance and step-by-step instructions for obtaining regulated soil and 

organism permits can be found at Plant Health Import Permits at http:// 

www.aphis.usda.gov/plant_health/permits/organism/biological_control/ 

weeds.shtml. 

B-1-8 TAG-BCAW Manual 10/2023-05 
 

 



  

 








Forms 

PPQ Form 526, Application to Move Live Plant Pests or Noxious Weeds 

PPQ Form 526, Application to Move Live Plant Pests or Noxious 

Weeds 

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I/We agree to comply with the safeguards printed on the 

reverse of this form, and understand that a permit may be 

subject to other conditions specified in Section B and C. 

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Figure B-1-5 PPQ Form 526, Application to Move Live Plant Pets or Noxious Weeds 

10/2023-05 TAG-BCAW Manual B-1-9 
Forms 

PPQ Form 526, Application to Move Live Plant Pests or Noxious Weeds 

Purpose 

PPQ Form 526, Application to Move Live Plant Pests or Noxious Weeds, is the 

application used to request a USDA-APHIS-PPQ permit for the following 

activities: 

Import plant pests, including but not limited to the following living 

organisms: biological control organisms, earthworms, honeybees and 

other pollinating bees, insects, mites, nematodes, slugs, snails; microbes 

pathogenic to plants or invertebrates; parasitic plants, or other Federal 

noxious weeds into the environment of the United States 

Ship interstate any of the above except entomophagous insects and 

honeybees 

Release any organisms including those for biological control purposes, 

from containment into the environment of the United States 

NOTICE 

Do not use this form (PPQ Form 526) for genetically-engineered plants or 

genetically-engineered plant pests. 

Use APHIS Form 2000 for genetically-engineered plants or genetically-engineered 

plant pests. 

Distribution 

See Instructions for Completing an Application for an APHIS Permit on page 

B-8. 

B-1-10 TAG-BCAW Manual 10/2023-05 
 

 

 

Forms 

PPQ Form 599, Import Label for Living Regulated Organisms (Red and White) 

PPQ Form 599, Import Label for Living Regulated Organisms (Red 

and White) 

Figure B-1-6 Example of PPQ Form 599, Import Label for Living Regulated 

Organisms (red and white shipping label) (adhesive label issued 

before September 9, 2014, but valid until expiration date on permit) 

Table B-1-1 PPQ Form 599, Import Label for Living Regulated Organisms (red 

and white label) Mailing or Shipping (new plain paper (nongummed) 

or special adhesive (gummed) label issued starting September 9, 

2014) 

10/2023-05 TAG-BCAW Manual B-1-11 
Forms 

PPQ Form 599, Import Label for Living Regulated Organisms (Red and White) 

Purpose 

PPQ Form 599, Import Label for Living Regulated Organisms (Red and 

White), is a red and white shipping label issued by the USDA-APHIS-PPQ 

Permit Unit to denote shipping or mailing regulated articles into the U.S. The 

PPQ Form 599 label designates a package as containing living organisms 

regulated under an APHIS PPQ permit (see PPQ Form 526, Application to 

Move Live Plant Pests or Noxious Weeds). The organisms (plant pests or 

pathogens) usually fall into one of the following categories: bees, biological 

control agents, live insects, noxious weeds, parasitic plants, plant pathogens, 

plant pests, select agents, snails, or worms. 

For shipping or mailing, the red and white label includes the APHIS permit 

number and the address where inspection is authorized. Inspections usually 

(but not always) occur at a PPQ plant inspection station. The label authorizes 

movement of a secure and intact package to the address on the label. 

APHIS is phasing in the use of printable plain paper (nongummed) labels for 

permitted Plant Protection and Quarantine imports that require a label. The 

new, plain paper labels are the ePermits default choice. The plain paper labels 

are sent via email to the permittee as a PDF attachment. The permittee may 

then distribute permit labels to shippers by email or regular mail. The shipper 

is instructed to print the plain paper label using a color, and then attach the 

label to the package exterior using clear tape. 

The permittee may request and be issued plain paper labels, special gum labels, 

or a combination of both. The permittee needs to specify either plain paper 

labels or special gum labels for each request. If both types of labels are issued 

for the same permit, then the label numbers remain sequential. There may be a 

slight change in appearance of the plain paper (nongummed) labels, because 

printer ink may vary in color and intensity and the labels will be affixed using 

clear tape. If there is a failure to print the labels in color, then shipments can 

and will be refused and/or ordered destroyed. 

Distribution 

PPQ Form 599, Import Label for Living Regulated Organisms (Red and White 

Label), is distributed by the USDA-APHIS-PPQ Pest Permitting Branch. 

B-1-12 TAG-BCAW Manual 10/2023-05 
NAPPO Standard Appendix 

C 

Contents 

Introduction C-1-1 

Requirements C-1-1 

Introduction 

The NAPPO Standard appendix provides the North American Plant Protection 

Organization (NAPPO) standard that may be used as a reference. This 

document is a regional (North American) plant protection standard agreed 

upon by Canada, Mexico, and the United States, outlining the minimum 

requirements for information to be included in a petition to regulatory officials. 

Additional information may be required by regulatory officials in one or more 

of these countries. 

NOTICE 

 

Petitioners in Canada and Mexico are required to follow the NAPPO Standard, 

RSPM 7, which is similar to the format in Format for Petitions for Field Release on 

page 5-1-2 and Format for Test Plant Lists on page 5-3-2. 

Requirements 

Each petition should be preceded by a title page, a table of contents, and a 

summary or abstract. 

Petitioners from the United States will follow the procedures as stated in 

Format for Petitions for Field Release on page 5-1-2 and Format for Test Plant 

Lists on page 5-3-2. Submitting a TAG-BCAW petition (following the 

procedures as stated in Petitions for Field Release Format of this manual) 

satisfies the NAPPO standard for proposed environmental releases in the U.S. 

Petitioners from Canada and Mexico will follow the NAPPO standard, RSPM 

7 Guidelines for Petition for First Release of Non-indigenous Phytophagous or 

Phytopathogenic Biological Control Agents from the NAPPO Regional 

Standards for Phytosanitary Measures. RSPM 7. 

10/2023-05 TAG-BCAW Manual C-1-1 
 

NAPPO Standard 

Requirements 

C-1-2 TAG-BCAW Manual 10/2023-05 
 

 

Appendix 

D 

Fish and Wildlife Service 

Offices 

Directory 

Content 

Introduction D-1-1 

U.S. Fish and Wildlife Service (FWS) Regional Offices D-1-1 

Introduction 

The Fish and Wildlife Service Offices appendix provides a list of U.S. Fish and 

Wildlife Service (FWS) Regional Offices and contact information. 

U.S. Fish and Wildlife Service (FWS) Regional Offices 

Petitioners and researchers may contact the appropriate U.S. FWS Regional 

Office early in the petition process for advice and input regarding Section 7 of 

the Endangered Species Act 

Table D-1-1 Directory of U.S. Fish and Wildlife Service (FWS) Regional Offices 

FWS Region Area of Coverage FWS Office Address Phone Number 

Region 1 Hawaii 

Idaho 

Oregon 

Washington 

Pacific Islands 

Division of Endangered Species 

U.S. Fish and Wildlife Service (FWS) 

911 NE 11th Avenue 

Portland, OR 97232-4181 

http://www.fws.gov/program/ecological-services/contact-us 

503-231-6151 

Region 2 Arizona 

New Mexico 

Oklahoma 

Texas 

Division of Endangered Species 

U.S. Fish and Wildlife Service (FWS) 

PO Box 1306 

Albuquerque, NM 87103-1306 

http://www.fws.gov/program/ecological-services/contact-us 

505-248-6651 

Region 3 Illinois 

Indiana 

Michigan 

Minnesota 

Missouri 

Ohio 

Wisconsin 

Division of Endangered Species 

U.S. Fish and Wildlife Service (FWS) 

5600 American Blvd. West, Suite 990 

Bloomington, MN55437-1458 

http://www.fws.gov/program/ecological-services/contact-us 

612-713-5334 

10/2023-05 TAG-BCAW Manual D-1-1 
 

Fish and Wildlife Service Offices 

U.S. Fish and Wildlife Service (FWS) Regional Offices 

Table D-1-1 Directory of U.S. Fish and Wildlife Service (FWS) Regional Offices (continued) 

FWS Region Area of Coverage FWS Office Address Phone Number 

Region 4 Alabama 

Arkansas 

Florida 

Georgia 

Kentucky 

Louisiana 

Mississippi 

North Carolina 

South Carolina 

Tennessee 

Connecticut 

Delaware 

District of Columbia 

Maine 

Maryland 

Massachusetts 

New Hampshire 

Division of Endangered Species 

U.S. Fish and Wildlife Service (FWS) 

1875 Century Boulevard, Suite 200 

Atlanta, GA 30345 

http://www.fws.gov/program/ecological-services/contact-us 

Division of Threatened and Endangered Species 

U.S. Fish and Wildlife Service (FWS) 

300 Westgate Center Drive 

Hadley, MA 01035-9589 

http://www.fws.gov/program/ecological-services/contact-us 

850-877-6513 

Region 5 413-253-8615 

New Jersey 

New York 

Pennsylvania 

Rhode Island 

Vermont 

Virginia 

West Virginia 

Colorado 

Kansas 

Montana 

Nebraska 

North Dakota 

South Dakota 

Utah 

Wyoming 

Mailing Address: 

Division of Endangered Species 

U.S. Fish and Wildlife Service (FWS) 

PO Box 25486, DFC 

Denver, CO 80225 

Physical Address: 

Division of Endangered Species 

U.S. Fish and Wildlife Service (FWS) 

Region 6 303-236-4046 

134 Union Blvd., Suite 650 

Lakewood, CO 80228 

http://www.fws.gov/program/ecological-services/contact-us 

Division of Endangered Species 

U.S. Fish and Wildlife Service (FWS) 

1011 East Tudor Road 

Anchorage, AK 99503 

http://www.fws.gov/program/ecological-services/contact-us 

Division of Endangered Species 

U.S. Fish and Wildlife Service (FWS) 

2800 Cottage Way, Suite W2606 

Sacramento, CA 95825 

http://www.fws.gov/program/ecological-service/contact-us 

907-786-3323 

916-414-6600 

Region 7 Alaska 

Region 8 California 

Nevada 

D-1-2 TAG-BCAW Manual 10/2023-05 
Plant Classification 

System 

Appendix 

E 

Contents 

Introduction E-1-1 

Plant Classification System E-1-1 

Introduction 

The Plant Classification System appendix provides information about the plant 

classification systems that are in use today. 

Plant Classification System 

The risk of non-target impacts is examined through host specificity testing of 

the proposed biological control agent of weeds. Post-release monitoring of 

control agents has shown that the highest level of risk is to those plants most 

closely related, in terms of phylogenetic (evolutionary) relatedness, to the 

target plant (Pemberton 2000). Construction of the host test plant list gives 

higher emphasis to those plants closely related to the target weed and less 

emphasis to more distantly related non-target plants. This method of test plant 

list construction is called the “Wapshere method” (after Wapshere (1974) who 

first proposed the method) or the “centrifugal phylogenetic method.” Two 

things are required for this method to be effective: accurate identification of the 

target weed and an accurate understanding of the target’s phylogenetic 

relationship with non-target plants. 

The field of plant taxonomy and systematics has undergone major changes in 

the last 30 years. The most profound is the development of molecular 

taxonomy and a corresponding systematics that has led to a large source of new 

data for use in phylogenetic analyses and a better understanding of the 

evolutionary relationships among plant groups. 

Changes in nomenclature and modification of phylogenetic hypotheses are ongoing. As a result, the best sources of current taxonomic nomenclature and 

plant phylogenies are Web sites that are updated frequently. 

For the current nomenclature of a target weed, petitioners should use accurate 

databases and consult with a plant taxonomist. 

04/2024-06 TAG-BCAW Manual E-1-1 
 

Plant Classification System 

Plant Classification System 

The use of molecular methods has also resulted in changes to our 

understanding of the evolutionary relationships among plants. In particular, 

molecular data have identified a number of traditional taxonomic groups that 

are polyphyletic and comprised of unrelated molecular lineages, that is, groups 

that have similar morphology due to convergent evolution but do not share a 

most recent ancestor. Conversely, some groups that appear morphologically 

dissimilar have been found to be closely related. A recent example of a major 

change to a traditional family is the breakup of the family Scrophulariaceae. 

Previously, this family contained a number of weedy genera, such as Linaria, 

Verbascum, and [now] Plantago. Recently, based on molecular data, it has 

been shown to have been composed of at least five distinct monophyletic 

groups (Olmstead et al. 2001). While the family Scrophulariaceae still exists, it 

is now comprised of only a few small genera, as each of the monophyletic 

groups has been merged with other families to which they are more closely 

related. 

A recent description of the phylogeny of plant families based on the latest 

molecular data was published by Haston et al. (2007) where an evolutionary 

tree illustrating the phylogeny was presented. Petitioners should consult this 

paper to learn what families are most closely related to the target weed’s 

family. 

Any changes and updates to Haston et al. are posted on the Angiosperm 

Phylogeny Web site, a website maintained by Peter Stevens of the Missouri 

Botanical Garden. Petitioners are to check this website and cite as follows: 

“Stevens, P. F. (date of access). Angiosperm Phylogeny Web site. Version #, 

date of last update.” 

References 

Haston, E., J. E. Richardson, P. F. Stevens, M. W. Chase, and D. J. Harris. 2007. A linear 

sequence of Angiosperm Phylogeny Group II families. Taxon 56(1): 7-12. 

Olmstead, R. G., C. W. dePamphilis, A. D. Wolfe, N. D. Young, W. J. Elisons, and P. A. Reeves. 

2001. Disintegration of the Scrophulariaceae. American Journal of Botany 88(2): 348-361. 

Pemberton, R. W. 2000. Predictable risk to native plants in weed biological control. Oecologia 

(Berlin) 125: 489–494. 

Wapshere, A. J. 1974. A strategy for evaluating the safety of organisms for biological weed control. Annals of Applied Biology 77: 201–211. 

E-1-2 TAG-BCAW Manual 04/2024-06 
References Appendix 

F 

Contents 

Introduction F-1-2 

General References F-1-2 

Articles F-1-2 

Books F-1-3 

Websites F-1-4 

Biological Control Agents F-1-5 

Articles F-1-5 

Audiovisual Materials F-1-6 

Books and Periodicals F-1-6 

Recognized Taxonomic Institutions F-1-8 

Websites F-1-9 

Biological Control of Weeds F-1-10 

Articles F-1-10 

Books F-1-12 

Websites F-1-13 

Economic Botany F-1-15 

Books F-1-15 

Websites F-1-15 

Plant Taxonomy and Distribution F-1-16 

Articles F-1-16 

Audiovisual Materials F-1-16 

Books F-1-16 

Websites F-1-18 

Protected Species F-1-20 

Websites F-1-20 

Risk Assessment F-1-21 

Articles F-1-21 

Books F-1-24 

Websites F-1-24 

Testing Methodology for Biological Control F-1-25 

Articles F-1-25 

Books F-1-28 

Websites F-1-28 

04/2024-06 TAG-BCAW Manual F-1-1 
 

References 

Introduction 

Introduction 

The References appendix contains a list of reading material suggested by the 

Technical Advisory Group for Biological Control Agents of Weeds (TAGBCAW). 

General References 

Articles 

Briese, D.T. 2004 “Weed biological control: applying science to solve 

seemingly intractable problems.” Australian Journal of Entomology 43: 304-

317. 

Clewley, G.D., R. Eschen, R.H. Shaw, and D.J. Wright. 2012. “The 

effectiveness of classical biological control of invasive plants.” Journal of 

Applied Ecology 49: 1287-1295. 

Cuda, J.P., R. Charudattan, M.J. Grodowitz, J.F. Shearer, R.M. Newman, M.L. 

Tamayo, and B. Villegas. 2008. “Recent advances in biological control of 

submersed aquatic weeds.” Journal of Aquatic Plant Management 46: 15-32. 

Culliney, T.W. 2005. “Benefits of classical biological control for managing 

invasive plants.” Critical Reviews in Plant Science 24: 131-150. 

Denoth, M.; L. Frid, and J.H. Meyers. 2002. “Multiple agents in biological 

control: improving the odds?” Biological Control 24: 20-30. 

Gaskin, John F., Marie-Claude Bon, Matthew J.W. Cock, Massimo Cristofaro, 

Alessio De Biase, Rose De Clerck-Floate, Carol A. Ellison, Harriet L. Hinz, 

Ruth A. Hufbauer, Mic H. Julien, and René Sforza. 2011. “Applying 

molecular-based approaches to classical biological control of weeds.” 

Biological Control 58: 1-21. 

Ghosheh, H.Z. 2005. “Constraints in implementing biological weed control: A 

review.” Weed Biology and Management 5: 83-92. 

Hoddle, Mark S. 2004. “Restoring balance: using exotic species to control 

exotic invasive species.” Conservation Biology 18: 38-49. 

Julien, Mic and Graham White (eds.). 1997. “Biological Control of Weeds: 

theory and practical application.” ACIAR Monograph 49: 1-192. 

F-1-2 TAG-BCAW Manual 04/2024-06 
 

 

 References

 General References 

Lym, R.G. 2005. “Integration of biological control agents with other weed 

management technologies: Successes from the leafy spurge (Euphorbia esula) 

IPM program.” Biological Control 35: 366-375. 

McFadyen, Rachel E. Cruttwell. 1998. “Biological Control of Weeds.” Annual 

Review of Entomology 43: 369-393. 

Mills, N.J. and J.M. Kean. 2010. “Behavioral studies, molecular approaches, 

and modeling: Methodological contributions to biological control success.” 

Biological Control 52: 255-262. 

Müller-Schärer, H. and U. Schaffner. 2008. “Classical biological control. 

exploiting enemy escape to manage plant invasions.” Biological Invasions 

10: 859-874. 

Olckers, T., and M.P. Hill (Eds). 1999. “Biological control of weeds in South 

Africa (1990-1998).” African Entomology Memoir No. 1 182. pp. 

Paynter, Q., J.M. Overton, R.L. Hill, S.E. Bellgard, and M.I. Dawson. 2012. 

“Plant traits predict the success of weed biocontrol.” Journal of Applied 

Ecology 49: 1140-1148. 

Raghu, S. and R.D. van Klinken. 2006. “Refining the Ecological Basis of 

Agent Selection in Weed Biological Control.” Australian Journal of 

Entomology 45(4): 251-365. 

Van Wilgen, B.W. and W. J. De Lange. 2011. “The costs and benefits of 

biological control of invasive alien plants in South Africa.” African 

Entomology 19. 504-514. 

Wang, Y., W. Huang, E. Siemann, Z. Jianwen, G.S. Wheeler, J. Carrillo, and J. 

Ding. 2011. “Lower resistance and higher tolerance of invasive host plants: 

biological control agents reach high densities but exert week control.” 

Ecological Applications 21:729-738. 

Books 

Coombs, E.M., J.K. Clark, G.L. Piper and A.F. Cofrancesco, Jr. (eds). 2004. 

Biological Control of Invasive Plants in the United States. Oregon: Oregon 

State University Press. 467 pp. 

Gurr, Geoff and Steve Wratten (eds). 2000. Biological Control: Measures of 

Success. Dordrecht, Netherlands: KluwerAcademic Publishers. 429 pp. 

Hajek, Ann E. 2004. Natural Enemies: An Introduction to Biological Control. 

Camridge, United Kingdom: Cambridge University Press. 378 pp. 

04/2024-06 TAG-BCAW Manual F-1-3 
 

References 

General References 

Julien, M. H., R.E.C. McFadyen, and J.M. Cullen (eds). 2012. Biological 

Control of Weeds in Australia. Melbourne, Australia: CSIRO Publishing. 

648 pp. 

Maniappan, R., G.V.P. Reddy and A. Raman (eds). 2009. Biological Control of 

Tropical Weeds Using Arthropods. Cambridge, United Kingdom: Cambridge 

University Press, 495 pp. 

Mason, P.G. and J.T. Huber (eds). 2013. Biological Control Programmes in 

Canada, 2001-2012. Wallingford, United Kingdom: CABI Publishing. 544 pp. 

Mason, P.G. and J.T. Huber (eds). 2001. Biological Control Programmes in 

Canada, 1981-2000. Wallingford, United Kingdom: CABI Publishing. 608 pp. 

Spafford, J.H. and D.T. Briese. 2002. Improving the Selection, Testing, and 

Evaluation of Weed Biological Control Agents. Technical Series No. 7, 

Adelaide, Australia: Cooperative Research Centre for Australian Weed 

Management. 7: 1-99. 110 pp. 

Van Driesche, R., M. Hoddle, and T. Center. 2008. Control of Pests and Weeds 

by Natural Enemies: An Introduction to Biological Control. Malden, MA: 

Blackwell Publishing. 473 pp. 

Withers, T.M., L. B. Brown, and J. Stanley (eds). 1999. Host Specificity Testing 

in Australasia: towards improved assays for biological control. Cooperoo, 

Queensland, Australia: Department of Natural Resource. 98 pp. 

Websites 

“Biological control of weeds,” CSIRO, last modified February 1, 2013. 

“Improving the Selection, Testing, and Evaluation of Weed Biological Control 

Agents,” CRC for Australian Weed Management, April 2003. 

F-1-4 TAG-BCAW Manual 04/2024-06 
 

 

 References

 Biological Control Agents 

Biological Control Agents 

Articles 

Bruckart, W.L. and N. Shishkoff. 1993. “Foreign plant pathogens for 

environmentally safe biological control of weeds.” In: Lumsden, R. D. and J.L. 

Vaughan (eds). Pest Management: Biologically Based Technologies. Beltsville 

Symposium - 18, American Chemical Society, Washington, DC. 224-230. 

Bruckart, W.L., D.M. Supkoff, and S.M. Yang. 1996. “Indigenous plant 

pathogens in evaluations of foreign biological control candidates in the United 

States of America.” In: Proceedings of the IX International Symposium on 

Biological Control of Weeds. Stellenbosch, South Africa. 

Cullen, J.M. 1988. “Current problems in host-specificity screening.” In 

Proceedings VII of the International Symposium of Biological Control of 

Weeds: 27-36. 

Franks, S.J., P.D. Pratt, and N.D. Tsutsui. 2011. “The genetic consequences of 

a demographic bottleneck in an introduced biological control insect.” 

Conservation Genetics 12: 201-211. 

Harris, Peter, and Peter McEvoy. 1995. “The predictability of insect host plant 

utilization from feed tests and suggested improvements for screening weed 

biological control agents.” Proceedings of the VII International Symposium of 

Biological Control of Weeds. Melbourne 125-131. DSI/CSIRO. 

Herrick, N. J. and L.T. Kok. 2010. “Classical biological control of weeds with 

Curculionidae.” CAB Reviews: Perspectives in Agriculture, Veterinary 

Science, Nutrition and Natural Resources 5 (028): 1-11. 

Morin, L., A.M. Reid, N.M. Sims-Chilton, Y.M. Buckley, K. Dhileepan, G.T. 

Hastwell, T.L. Nordblom, and S. Raghu. 2009. “Review of approaches to 

evaluate the effectiveness of weed biological control agents.” Biological 

Control 51: 1-15. 

Myers, J.H., C. Jackson, H. Quinn, S.R. White, and J.S. Cory, 2009. 

“Successful biological control of diffuse knapweed, Centaurea diffusa, in 

British Columbia, Canada.” Biological Control 50: 66-72. 

Paynter, Q., and S. Bellgard. 2011. “Understanding dispersal rates of invading 

weed biocontrol agents.” Journal of Applied Ecology. 48: 407-414. 

Schwarzlaender, M., H.L. Hinz, and R. Wittenberg. 1996. “Oogenesis 

requirements and weed biological control: an essential part in host-range 

04/2024-06 TAG-BCAW Manual F-1-5 
 

References 

Biological Control Agents 

evaluation of insect agents or just wasted time?” Proceedings of the IX 

International Symposium on Biological Control of Weeds. Stellenbosch, South 

Africa: University of Cape Town. 79-85. 

Shearer, J.F. 2012. “A historical perspective of pathogen biological control of 

aquatic plants.” Weed Technology 24: 202-207. 

Skoracka, A.L., L. Smith, G. Oldfield, M. Cristofaro, and J. Amrine. 2010. 

“Host-plant specificity and specialization in eriophyoid mites and their 

importance for the use of eriophyoid mites as biocontrol agents of weeds.” 

Experimental and Applied Acarology 51: 93-113. 

Smith, L., E. de Lillo, and J. Amrine. 2010. “Effectiveness of eriophyid mites 

for biological control of weedy plants and challenges for future research.” 

Experimental and Applied Acarology 51(1-3): 115-149. 

Van Hezewijk, B.H., R.S. Bourchier, and R.A. De Clerck-Floate. 2010. 

“Regional-scale impact of the weed biocontrol agent Mecinus janthinus on 

Dalmation toadflax (Linaria dalmatica).” Biological Control 55(3): 197-202. 

Audiovisual Materials 

Noxious and Nuisance Plant Management Information System (PMIS). CDROM. U.S. Army Corps of Engineers, Waterways Experiment Station, 

Vicksburg, MS. 

Books and Periodicals 

Batra, S.W.T., J.R. Coulson, P.H. Dunn, and P.E. Boldt. 1981. “Insects and 

fungi associated with carduus thistles.” USDA ARS Technical Bulletin 

1616.1981.100 pp. 

Center, T.D., G. Jubinsky, and F. Dray. 1992. “Biological control of aquatic 

weeds, insects that feed on aquatic plants.” In: Biology and Identification 

Manual. 

Coulson, J.R. 1977. “Biological control of alligatorweed, 1959-1972: a review 

and evaluation. USDA, Technical Bulletin 1547. 

Goeden, R.D. 1978. “Biological control of weeds.” In: Introduced parasites 

and predators of arthropod pests and weeds: a world review. U.S. Department 

of Agriculture, Handbook 480: 357–414. 

Harley, K.L.S. and I.W. Forno. 1992. Biological control of weeds; a handbook 

for practitioners and students. Melbourne: Inkata Press. 74pp. 

F-1-6 TAG-BCAW Manual 04/2024-06 
 

 

 References

 Biological Control Agents 

Julien, M.H. 1992. Biological Control of Weeds: A world catalogue of agents 

and their target weeds. Third edition. Wallingford: CAB International. 

Julien, M.H. (author) and M.W. Griffiths (ed.). 1998. Biological Control of 

Weeds: a World Catalogue of Agents and their Target Weeds. 4th edition. CABI 

Publishing, Wallingford, United Kingdom. 

McFadyen, Rachel E.Crutwell. 1998. “Biological Control of Weeds.” Annual 

Review of Entomology 43: 369-393. 

Rees, N.E., P.C. Quimby, G.L. Piper, E.M. Coombs, C.E. Turner, N.R. Spencer, 

and L.V. Knutson. 1996. Biological Control of Weeds in the West. Western 

Society of Weed Science. 

Van Driesche, R., S. Lyon, B. Blossey, M. Hoddle, and R.Reardon. 2002. 

Biological Control of Invasive Plants in the Eastern United States. USDA 

Forest Service. Forest Health Technology Enterprise Team Publication. 

FHTET -2002-04. 413 pp. 

04/2024-06 TAG-BCAW Manual F-1-7 
 

References 

Biological Control Agents 

Recognized Taxonomic Institutions 

United States 

USDA, ARS, Plant Sciences Institute 

Systematic Entomology Laboratory 

Bldg. 005, Room 133, BARC-West 

10300 Baltimore Blvd. 

Beltsville, MD 20705-2350 

USDA, ARS 

Systematic Mycology and Microbiology Laboratory 

Dr. Amy Rossman, Mycology 

Bldg. 011A, Room 304, BARC-West 

10300 Baltimore Avenue 

Beltsville, MD 20705 

USDA, ARS 

National Germplasm Resources Laboratory 

Dr. John Wiersema, Plant Taxonomy 

Building 003, Room 124, BARC-West 

Beltsville, MD 20705-2350 

E-mail: john.wieersema@ars.usda.gov 

Canada 

Dr. Owen Lonsdale, Collections Manager 

Canadian National Collection of Insects, Arachnids and Nematodes 

Agriculture and Agri-Food Canada/Agriculture et Agroalimentaire Canada 

KW Neatby Building 

960 Carling Avenue 

Ottowa, ON KIA 0C6 

CANADA 

Telephone/Téléphone: 613-759-1992 

FAX/Télécopieur: 613-759-1927 

Email: owen.lonsdale@agr.gc.ca 

Mexico 

Colecciòn Nacional de Insectos 

Instituto de biologia, UNAM 

Aprtado Postal 70-153 

04510 Mèxico, D.F.

MÈXICO 

Telephone 56-22-91-67 ext. 47821 

Email: mayorga@ibiologia.unam.mx 

F-1-8 TAG-BCAW Manual 04/2024-06 
 

 

 References

 Biological Control Agents 

Websites 

“BCANZ—Biological Control Agents introduced to New Zealand,” Ferguson, 

C.M., Moeed, A., Barrett, B.I.P., Hill, R.L., and Kean, J.M, Better Border 

Security New Zealand, 2007. 

“Biological Control: A Guide to Natural Enemies in North America - Weedfeeders,” Cornell University. New York State Agricultural Experiment Station, 

Department of Entomology, accessed June 17, 2013. 

“Biological Control of Pests in the Forests of Eastern United States,” 

University of Massachusetts Amherst, accessed June 17, 2013. 

“Publications, Biological Control,” United States Department of Agriculture, 

Forest Service, accessed June 17, 2013. 

“Releases of Beneficial Organisms in the United States and Territories 

(ROBO)” United States Department of Agriculture, Agriculture Research 

Service, National Invertebrate Genetic Resources, Biological Control 

Documentation Center, accessed June17, 2013). 

04/2024-06 TAG-BCAW Manual F-1-9 
 

References 

Biological Control of Weeds 

Biological Control of Weeds 

Articles 

Cavers, P.B. (ed.). 1995. “The Biology of Canadian Weeds.” Agricultural 

Institute of Canada, Ottawa, Ontario, Canada, 3: 62-83. 

Cavers, P.B., and S.I. Warwick. 2000. “The Biology of Canadian Weeds.” 

Canadian Journal of Plant Science 80: 237-240. 

Cavers, P.B., S.I. Warwick, and D.R. Clements. 2003. “The Biology of 

Canadian Weeds.” Canadian Journal of Plant Science 83: 661-665. 

Cavers, P.B. (ed). 2005. “The Biology of Canadian Weeds.” Agricultural 

Institute of Ottawa, Ontario, Canada. 5:103-129 

Cripps, M.G., A. Gassmann, S.V. Fowler, G.W. Bourdôt, A.S. McClay, and 

G.R. Edwards. 2011. “Classical biological control of Cirsium arvense: Lessons 

from the past.” Biological Control 57: 165-174. 

Coulson, Jack R. 1992. “Documentation of classical biological control 

introductions.” Crop Protection 11(3): 195–205. 

Cullen, J.M. 1988. “Current problems in host-specificity screening.” 

Proceedings of the VII International Symposium of Biological Control of 

Weeds. Melbourne. 27–36. 

Cullen, J.M. 1995. “Predicting effectiveness: fact and fantasy.” Proceedings of 

the VIII International Symposium of Biological Control of Weeds. Melbourne. 

103–109. 

Dunn, P.H. 1976. “Shortcomings in classic tests of candidate insects for the 

biocontrol of weeds.” Proceedings of the IV International Symposium on 

Biological Control of Weeds; Gainesville, FL51–56. 

Harris, P., and H. Zwölfer. 1968. “Screening phytophagous insects for 

biological control of weeds.” The Canadian Entomologist 100: 295–303. 

Harris, Peter, and P. McEvoy. 1995. “The predictability of insect host plant 

utilization from feeding tests and suggested improvements for screening weed 

biological control agents.” Proceedings of the VIII International Symposium of 

Biological Control of Weeds; Melbourne: 125–131. 

Hoffmann, J.R. 1991. “Biological control of weeds in South Africa.” 

Agriculture, Ecosystems and Environment 37: 255. 

F-1-10 TAG-BCAW Manual 04/2024-06 
 

 

 References 

Biological Control of Weeds 

Klingman, D.L., and J.K. Coulson. 1983. “Guidelines for introducing foreign 

organisms into the United States for the biological control of weeds.” Bulletin 

of the Entomological Society of America 29 (3): 55–61. 

Lesica, Peter, and Dave Hanna. 2009. “Effect of Biological Control on Leafy 

Spurge (Euphorbia esula) and Diversity of Associated Grasslands over 14 

Years.” Invasive Plant Science and Management 2: 151-157. 

McClay, A.S. 1989. “Selection of suitable target weeds for classical biological 

control in Alberta.” Alberta Environmental Centre, Vegreville, AECV89-R1. 

McFadyen, Rachel E. Cruttwell. 1998. “Biological Control of Weeds.” Annual 

Review of Entomology 43: 369-93. 

Morin, L., A.M. Reid, N.M. Sims-Chilton, Y.M. Buckley, K. Dhileepan, G.T. 

Hastwell, T.L. Nordblom, and S. Raghu. 2009. “Review of approaches to 

evaluate the effectiveness of weed biological control agents.” Biological 

Control 51: 1-15. 

Myers, Judith H., Caroline Jackson, Hillary Quinn, Shannon R. White, and 

Jenny S. Cory. 2009. “Successful biological control of diffuse knapweed, 

Centaurea diffusa, in British Columbia, Canada.” Biological Control 50: 66-

72. 

Samuel L.W., D.R. Kirby, J.E. Norland, G.L. Anderson. 2008. “Leafy spurge 

suppression by flea beetles in the Little Missouri Drainage Basin, U.S.A. 

Rangeland Ecology and Management 61: 437-443. 

Shepherd, Rosamond C.H. 1989. “Problems which arise with host-specificity 

testing of insects.” Proceedings of the VII International Symposium of 

Biological Control of Weeds; 6–11 March 1988; Rome, Italy: Instituto 

Sperimentale per la Patologia Vegetale (MAF): 85–92. 

Van Hezewijk, B.H., R.S. Bourchier, and R.A. De Clerck-Floate. 2010. 

“Regional-scale impact of the weed biological control agent Mecinus janthinus 

on Dalmatian toadflax (Linaria dalmatica).” Biological Control 55: 197-202. 

Wapshere, A.J. 1974a. “Host specificity of phytophagous organisms and the 

evolutionary centres of plant genera or sub-genera.” Entomophaga 19: 301– 

309. 

Wapshere, A.J. 1974b. “A strategy for evaluating the safety of organisms for 

biological weed control.” Annals Applied Biology 77: 201–211 

04/2024-06 TAG-BCAW Manual F-1-11 
 

References 

Biological Control of Weeds 

Wood, R.K.S., and M.J. Way (eds). 1988. “Biological control of pests, 

pathogens and weeds: developments and prospects.” Proceedings of a Royal 

Society Discussion Meeting; London. 

Zwölfer, H., and P. Harris. 1971. “Host specificity determination of insect for 

biological control of weeds.” Annual Review of Entomology 16: 159–178. 

Books 

Andres, L.A., C.J. Davis, P. Harris, and A.J. Wapshere. 1976. “Biological 

control of weeds.” In: Theory and Practice of Biological Control. New York: 

Academic Press, 481–499. 

Charudattan, R. and H.L. Walker (eds). 1982. Biological control of weeds with 

pathogens. New York: John Wiley & Sons. 293 pp. 

Coombs, E.M., Clark, J.K., Piper, G.L., and A.F. Cofrancesco, Jr. (eds). 2004. 

Biological Control of Invasive Plants in the United States. Oregon: Oregon 

State University Press. 448 pp. 

Coulson, J.R. 1977. Biological control of alligatorweed, 1959-1972: a review 

and evaluation. USDA, Technical Bulletin 1547. 98 pp. 

Coulson, J.R., P.V. Vail, M.E. Dix, D.A. Nordlund, and W.C. Kauffman (eds). 

110 Years of biological control research and development in the United States 

Department of Agriculture. In Press, U.S. Department of Agriculture. 

DeLoach, C.; H.A.Cordo; and I.S de Crouzel. 1989. Control biológico de 

malezas. El Ateneo, Buenos Aries. 266 pp. 

Harley, K.L.S.; and I.W. Forno. 1992. Biological Control of Weeds: A 

Handbook for Practitioners and Students. Melbourne: Inkata Press. 27–36, 

74 pp. 

Kelleher, J.S., and M.A. Hulme (eds). 1984. Biological control programmes 

against insects and weeds in Canada 1969-1980. Commonwealth Agriculture. 

Bureaux 410 pages. 

Mason, P.G., and J.T. Huber, 2002. Biological Control Programmes in Canada, 

1981-2000. CABI Publishing. 

Mulligan, G.A. (ed.). 1979. The Biology of Canadian Weeds: Volume 1, 

Contributions 1-32. Agriculture Canada, Ottawa, Ontario, Canada, Publication 

1693. 380 pp. 

F-1-12 TAG-BCAW Manual 04/2024-06 
 

 

 References 

Biological Control of Weeds 

Mulligan, G.A. (ed.). The Biology of Canadian Weeds: Volume 2, Contributions 

33-61, Agriculture Canada, Ottawa, Ontario, Canada, Publication 1765, 

415 pp. 

TeBeest, D.O. (ed). 1991. Microbial control of weeds. Chapman and Hall. 

284 pp. 

Van Driesche, R.G.; Bellows, T.S., Jr. 1996. Biology of weed control agents. In: 

Biological control. New York, NY: Chapman & Hall. 539 pp. 

Van Driesche, R., S. Lyon, B. Blossey, M. Hoddle, R. Reardon. 2002. 

Biological Control of Invasive Plants in the Eastern United States. USDA 

Forest Service. Forest Health Technology Enterprise Team Publication 

FHTET-2002-04. 413 pp. 

Waterhouse, D.F. 1994. Biological control of weeds: Southeast Asian 

prospects.ACIAR. Canberra. 302 p. 

Websites 

“BCANZ-Biological Control Agents introduced to New Zealand,” Ferguson, 

C.M., Moeed, A., Barrett, B.I.P., Hill, R.L., and Kean, J.M, Better Border 

Security New Zealand, 2007. 

“Best Practice Guide: Release and Establishment of Weed Biological Control 

Agents,” CRC for Australian Weed Management, accessed March 4, 2014. 

“Biological Control: A Guide to Natural Enemies in North America-Weed 

Feeders,” Cornell University, New York State Agricultural Experiment Station, 

Department of Entomology, Shelton, Anthony, accessed March 4, 2014. 

“Biological Control for Nature – Biological Control of Pests in Forests and 

Associated Habitats,” University of California – Riverside, accessed June 17, 

2013. 

“Biological Control of Pests in the Forests of Eastern United States,” 

University of Massachusetts Amherst, 2009. 

“CABI current invasive species projects”, CABI, accessed June 17, 2013. 

“Control Mechanisms,” USDA National Invasive Species Information Center, 

accessed June 17, 2013. 

“Idaho's BLM/ISDA Biological Control Program,” State of Idaho – 

Agriculture, accessed March 4, 2014. 

04/2024-06 TAG-BCAW Manual F-1-13 
 

References 

Biological Control of Weeds 

“Invasive Plant Management: Control Methods – Biological Control,” Center 

for Invasive Species Management, accessed March 4, 2014. 

“Noxious Weeds Program Home Page,” United States Department of 

Agriculture, Animal and Plant Health Inspection Service, last modified 

January 20, 2023. 

“Plant Health (PPQ),” United States Department of Agriculture, Animal and 

Plant Health Inspection Service, Plant Protection and Quarantine, accessed 

June 17, 2013. 

“Technical Advisory Group for Biological Control Agents of Weeds,” United 

States Department of Agriculture, Animal and Plant Health Inspection Service, 

Plant Protection and Quarantine, last modified April 28, 2021. 

“The Weed’s News – biological control,” The Weed’s Network, accessed 

March 4, 2014. 

F-1-14 TAG-BCAW Manual 04/2024-06 
 

 

 References

 Economic Botany 

Economic Botany 

Books 

Bailey, Liberty Hyde. 1949. Manual of Cultivated Plants. New York: 

Macmillan Publishing Company. 1116 pp. 

Fernald, M.L. (ed). 1970. Gray’s Manual of Botany. New York: D. Van 

Nostrand Co. 1632 pp. 

Bailey, L.H., and Ethel Zoe Bailey. 1976. HORTUS THIRD: a concise 

dictionary of plants cultivated in the United States and Canada. New York: 

Macmillan Publishing Company. 1312 pp. 

Howes, F.N. 1974. A Dictionary of Useful and Everyday Plants and Their 

Common Names. New York: Cambridge University Press. 294 pp. 

Isaacson, R.T. (ed). 2000. Andersen Horticultural Library’s Source List of 

Plants and Seeds: a completely revised listing of 1996-2000 catalogues. 

Chanhassen: The Library. 311 pp. 

Uphof, J.C. 1968. Dictionary of economic plants. New York: Stechert-Hafner. 

591 pp. 

Whitson, T.D., L.C. Burrill, S.A. Dewey, D.W. Cudney, B.E. Nelson, R.D. Lee, 

and R. Parker. 2009. Weeds of the West. 10th edition. Laramie: Western Society 

of Weed Science. 630 pp. 

Wiersema, J.H., and B. Leon. 2013. World Economic Plants: A Standard 

Reference. 2nd Edition. CRC Press. 1336 pp. 

Websites 

“Interactive Ecological Atlas of Russia and Neighboring Countries: Economic 

Plants and Their Diseases, Pests and Weeds,” Afonin, A.N., S.L. Greene, N.I 

Dzyubenko, A.N. Frolov, USDA-ARS and St. Petersburg State University. 

2008. 

04/2024-06 TAG-BCAW Manual F-1-15 
 

References 

Plant Taxonomy and Distribution 

Plant Taxonomy and Distribution 

Articles 

APG III: Brigitta Bremer, K Kåre Bremer, Mark W. Chase, Michael F. Fay, 

James L. Reveal, Douglas E. Soltis, Pamela S. Soltis and Peter F. Stevens with 

contributions from Arne A. Anderberg, Michael J. Moore, Richard G. 

Olmstead, Paula J. Rudall, Kenneth J. Sytsma, David C. Tank, Kenneth 

Wurdack, Jenny Q.-Y. Xiang, and Sue Zmarzty. 2009. “An update of the 

Angiosperm Phylogeny Group classification for the orders and families of 

flowering plants: APG III.” Botanical Journal of the Linnean Society. 161: 

105-121. 

Cavers, P.B. (ed.). 1995. “The Biology of Canadian Weeds: Volume 3”, 

Contributions 62-83. Agricultural Institute of Canada, Ottawa, Ontario, 

Canada, 338 pp. 

Cavers, P.B. 2000. “The Biology of Canadian Weeds: Volume 4.” 

Contributions 84-102, plus 3 updated contributions. Agricultural Institute of 

Ottawa, Ontario, Canada, 338 pp. 

Cavers, P.B. 2005. The Biology of Canadian Weeds. Volume 5. Contributions 

103-129, plus 3 updated contributions. Agricultural Institute of Ottawa, 

Ontario, Canada, 516 pp. 

Mulligan, G.A. (ed). 1979. “The Biology of Canadian Weeds: Volume 1.” 

Contributions 1-32. Agriculture Canada, Ottawa, Ontario, Canada, Publication 

1693. 380 pp. (book?) 

Mulligan, G.A. (ed). “The Biology of Canadian Weeds: Volume 2.” 

Contributions 33-61, Agriculture Canada, Ottawa, Ontario, Canada, 

Publication 1765, 415 pp. (book?) 

Audiovisual Materials 

Noxious and Nuisance Plant Management Information System (PMIS), U.S. 

Army Corps of Engineers, Waterways Experiment Station, Vicksburg, MS. 

(CD) 

Purge S P U R G E: Leafy Spurge Database. Version 3.0. USDA, ARS in 

cooperation with Montana State University. Directed by Neal R. Spencer. (CD) 

Books 

Bailey, L.H.; and Ethel Zoe Bailey. 1976. HORTUS THIRD: a concise 

dictionary of plants cultivated in the United States and Canada. New York: 

Macmillan Publishing Company. 1312 pp. 

F-1-16 TAG-BCAW Manual 04/2024-06 
 

 

 References

 Plant Taxonomy and Distribution 

Brako, Lois, and Amy Y. Rossman, David F. Farr. 1995. Scientific and 

Common Names of 7,000 Vascular Plants in the United States. St. Paul: 

American Phytopathological Society. 301 pp. 

Bremer, Kare. 1994. ASTERACEAE: CLADISTICS AND CLASSIFICATION. 

Portland: Timber Press. 752 pp. 

Cronquist, Arthur. 1993. The Evolution and Classification of Flowering 

Plants. New York; The New York Botanical Garden. 556 pp. 

Fernald, M.L. 1970. Gray’s Manual of Botany. New York: D. Van Nostrand 

Company. 1632 pp. 

Funk, V.A., T. Stuessy, and R. Bayer. 2009. Systematics, Evolution, and 

Biogeography of Compositae. Vienna: International Association for Plant 

Taxonomy. 965 pp. 

Gunn, Charles., John Wiersema, J.H., Carole Ritchie, and Joseph Kirkbride, Jr. 

1992. Families and Genera of Spermatophytes Recognized by the Agricultural 

Research Service. Washington, DC: USDATechnical Bulletin 1796. 500 pp. 

Isaacson, Richard T. (ed). 2004. Andersen Horticultural Library’s Source List 

of Plants & Seeds. Minnesota: University of Minnesota. 367 pp. 

Kartesz, J.T. 1994. A Synonymized Checklist of the Vascular Flora of the 

United States, Canada, and Greenland. Portland: Timber Press, Inc. 1504 pp. 

Mabberley, D.J. 2008. Mabberley’s Plant Book: A portable dictionary of 

plants, their classifications, and uses. Third edition. Cambridge: Cambridge 

University Press. 1021 pp. 

Terrell, Edward E. 1986. A Checklist of names for 3,000 vascular plants of 

economic importance. Washington, DC: U.S. Department of Agriculture, 

Agriculture Handbook No. 505. 

Willis, J.C. (revised by H.K. Airy Shaw) 1988. A dictionary of the flowering 

plants and ferns. Cambridge: University Press. 1245 pp. 

04/2024-06 TAG-BCAW Manual F-1-17 
 

References 

Plant Taxonomy and Distribution 

Websites 

“Annotated Checklist of the Panarctic Flora (PAF) Vascular Plants,” Elven, R. 

(Editor-in-Chief), accessed July 17, 2013. 

“Endangered Species,” U.S. Fish and Wildlife Service, accessed July 18, 2013. 

“Families and genera of spermatophytes recognized by the Agricultural 

Research Service,” Gunn, C.R., Wiersema, J.H., Kirkbride, J.H. Jr., and 

Ritchie, C.A, United States Department of Agricuture,1992, accessed July 17, 

2013. 

“Flora Europeae,” Royal Botanic Garden Edinburgh, Inverleith Row, 

Edinburgh, EH3 5LR, United Kingdom, last modified January 2011. 

“Flora of North America,” Flora of North America Association, last modified 

May 24, 2023. 

“The Global Plant Checklist Project,” IOPI, International Organization for 

Plant Information, accessed July 17, 2013. 

“The information resource for Euro-Mediterranean plant diversity,” Euro+Med 

PlantBase, accessed July 17, 2013. 

“Integrated Taxonomic Information System on-line database,” ITIS, 2013. 

“The International Plant Names Index,” The Royal Botanic Gardens, Kew, The 

Harvard University Herbaria, and The Australian National Herbarium, 2012. 

“The Jepson Online Interchange California Floristics,” University of 

California, Berkeley, 2013. 

“National Wildlife Federation,” National Wildlife Federation, Merrifield, 

Virginia, accessed July 17, 2013. 

“North American Vascula Flora,” The Biota of North America Program 

(BONAP), 2013. 

“The PLANTS Database,” USDA, NRCS, National Plant Data Team, 

Greensboro, North Carolina, USA, 2013. 

“The Plant List Version 1,” Royal Botanic Gardens, Kew and Missouri 

Botanical Garden, 2010. 

“Purge Spurge: Leafy Spurge Database,” NCSU, North Dakota State 

University, Fargo, North Dakota, accessed July 17, 2013. 

F-1-18 TAG-BCAW Manual 04/2024-06 
 

 

 References

 Plant Taxonomy and Distribution 

“The Tree of Life Web Project,” Maddison, D. R. and K.-S. Schulz (eds.), 

2007. 

“Vascular Plant Family Nomenclature,” James L. Reveal, University of 

Maryland, College Park, November 27, 2004. 

“USDA-APHIS Concordance of Family Names,” James L. Reveal, The 

Department of Plant Biology at Cornell University, University of Maryland, 

College Park, and the New York Botanical Garden. 

“USDA-ARS Germplasm Resources Information Network (GRIN),” USDA, 

ARS, National Genetic Resources Program, National Germplasm Resources 

Laboratory, Beltsville, Maryland, accessed July 17, 2013. 

04/2024-06 TAG-BCAW Manual F-1-19 
 

References 

Protected Species 

Protected Species 

Websites 

“COSEWIC – Committee on the Status of Endangered Wildlife in Canada,” 

COSEWIC, accessed July 18, 2013. 

“Environmental Conservation Online System: Threatened and Endangered 

Species,” U.S. Fish and Wildlife Service, accessed July 2013. 

“List of Endangered and Threatened Species, including Candidate Species,” 

U.S. Fish and Wildlife Service, accessed March 4, 2014. 

“The National Wildlife Federation,” The National Wildlife Federation, 

accessed July 2013. 

“Native Plant Network,” USDA Forest Service and Southern Regional 

Extension Forestry, accessed July 2013. 

“The PLANTS Database,” USDA, NRCS, National Plant Data Team, 

Greensboro, North Carolina, USA, 2013. 

“Species at risk public registry,” Environment Canada, last modified July 4, 

2023. 

“U.S. Fish and Wildlife Service,” U.S. Fish and Wildlife Service, accessed July 

2013. 

F-1-20 TAG-BCAW Manual 04/2024-06 
 

 

 References

 Risk Assessment 

Risk Assessment 

Articles 

Anderson, M.C., M. Ewald, and J. Northcott. 2005. “Risk analysis and 

management decisions for weed biological control agents: Ecological theory 

and modeling results.” Biological Control 35: 330-337. 

Barratt, B.I.P. 2011. “Assessing safety of biological control introductions.” 

CAB Reviews: Perspectives in Agriculture, Veterinary Science, Nutrition, and 

Natural Resources 6 (42): 1-12. 

Bourchier, R.S., and L.S. McCarty. 1995. “Risk assessment of biological 

control (predators and parasitoids).” Bulletin of the Entomological Society of 

Canada 27(3): 126–138. 

Briese, D.T. 2004. “Weed biological control: Applying science to solve 

seemingly intractable problems.” Australian Journal of Entomology 43: 304-

317. 

Carson, W.P., S.M. Hovick, A.J. Baumert, D.E. Bunker, and T.H. Pendergast, 

IV. 2008. “Evaluating the post-release efficacy of invasive plant biocontrol by 

insects: a comprehensive approach.” Arthropod-Plant Interactions 2: 77-86. 

Cook, R. James, William L. Bruckart, Jack R. Coulson, Mark S. Goettel, 

Richard A. Humber, Robert D. Lumsden, Joseph V. Maddox, Michael L. 

McManus, Larry Moore, Susan F. Meyer, Paul C. Quimby, Jr., James, P. Stack, 

and James LVaughn. 1996. “COMMENTARY: Safety of Microorganisms 

Intended for Pest and Plant Disease Control: A Framework for Scientific 

Evaluation. Biological Control 7: 333–351. 

Cullen, J.M. 1988. “Current problems in host-specificity screening.” 

Proceedings VII of the International Symposium of Biological Control of 

Weeds 27–36. 

Cullen, J.M. 1995. “Predicting effectiveness: fact and fantasy.” Proceedings of 

the VIII International Symposium of Biological Control of Weeds Melbourne. 

DSIR/CSIRO. 

Culliney, T.W. 2005. “Benefits of classical biological control for managing 

invasive plants.” Critical Reviews in Plant Sciences 24: 131-150. 

Delfosse, Ernest S. 2005. “Risk and ethics in biological control.” Biological 

Control 35 (2005): 319-329. 

04/2024-06 TAG-BCAW Manual F-1-21 
 

References 

Risk Assessment 

Fowler, Simon.V., Pauline Styrett, and Richard L. Hill. 2000. “Success and 

safety in the biological control of environmental weeds in New Zealand.” 

Austral Ecology 25: 553-562. 

Harris, Peter, and Peter McEvoy. 1995. “The predictability of insect host plant 

utilization from feeding tests and suggested improvements for screening weed 

biological control agents.” Proceedings of the VIII International Symposium of 

Biological Control of Weeds 125–131. 

Hogarth, F.G. 1990. “Environmental impacts of classical biological control.” 

Annual Review of Entomology 36: 485-509. 

[IPPC] International Plant Protection Convention. 2007. International 

Standards for Phytosanitary Measures No. 2: Framework for Pest Risk 

Analysis. Secretariat of the International Plant Protection Convention. FAO, 

Rome, 15 pp. 

[IPPC] International Plant Protection Convention. 2005. International 

Standards for Phytosanitary Measures No. 3: Guidelines for the Export, 

Shipment, Import and Release of Biological Control Agents and Other 

Beneficial Organisms. Secretariat of the International Plant Protection 

Convention. FAO, Rome, 26 pp. 

[IPPC] International Plant Protection Convention. 2004. International 

Standards for Phytosanitary Measures No. 11: Pest Risk Analysis for 

Quarantine Pests Including Analysis of Environmental Risks and Living 

Modified Organisms. Secretaria of the International Plant Protection 

Convention. FAO, Rome, 12 pp. 

Louda, S.M., R.W. Pemberton, M.T. Johnson, and P.B. Follett. 2003. “Nontarget effects—the Achilles’ heel of biological control? Retrospective analyses 

to reduce risk associated with biocontrol introductions.” Annual Review of 

Entomology 48: 365-396. 

McCoy, Earl D., and J.H. Frank. 2010. “How should the risk associated with 

the introduction of biological control agents be estimated?” Agricultural and 

Forest Entomology 12: 1-8. 

Pearson, D.E. and R.M. Callaway, 2005. “Indirect effects of host-specific 

biological control agents: Implications for biological control.” Biological 

Control 35: 288-298 

Pemberton, P.D., and T.D. Center. 2012. “Biocontrol without borders: the 

unintended spread of introduced weed biological control agents.” BioControl 

57: 319-319. 

F-1-22 TAG-BCAW Manual 04/2024-06 
 

 

 References

 Risk Assessment 

Pemberton, Robert W. 2000. “Predictable risk to native plants in weed 

biological control.” Oecologia 125 (4): 489-494. 

Raghu, S., K. Dhileepan and J.C. Scanlan. 2007. “Predicting risk and benefit a 

priori in biological control of invasive plant species: A systems modeling 

approach.” Ecological Modelling 208 (2-4): 247-262. 

Schwarzläender, M.; H.L. Hinz, and R. Wittenberg. 1996. “Oogenesis 

requirements and weed biocontrol: an essential part in host-range evaluation of 

insect agents or just wasted time?” Proceedings of the IX International 

Symposium on Biological Control of Weeds. Stellenbosch, South Africa: 

University of Cape Town. 79–85. 

Sheppard, A.W., R.D. van Klinken, and T.A. Heard. 2005. “Scientific advances 

in the analysis of direct risks of weed biological control agents to nontarget 

plants.” Biological Control 35: 215-226. 

Sheppard, A.W., R.H ill, R.A. De Clerck-Floate, A. McClay, T. Olckers, P.C. 

Quimby Jr., and H.G. Zimmermann. 2003. “A global review of risk-benefitcost analysis for the introduction of classical biological control agents against 

weeds: a crisis in the making?” Biocontrol News and Information 24(4): 91N108N. 

Simberloff, D., and P. Stiling. 1996. “Risks of Species introduced for 

biological control.” Biological Conservation 78: 185-192. 

Sing, Sharlene E., and Robert K.D. Peterson. 2011. “Assessing Environmental 

Risks for Established Invasive Weeds: Dalmation (Linaria dalmatica) and 

Yellow (L. vulgaris) Toadflax in North America.” International Journal of 

Environmental Research and Public Health 8: 2828-2853 

Van Klinken, R.D., and O.R. Edwards. 2002. “Is host specificity of weed 

biological control agents likely to evolve rapidly following establishment?” 

ECOLOGY LETTERS 5: 590-596. 

Wright, Mark G., Michael P. Hoffman, Thomas P. Kuhar, Jeffery Gardner, and 

Sylvie A. Pitcher. 2005. “Evaluating risks of biological control introductions: 

A problemistic risk-assessment approach.” Biological Control 35: 338-347. 

04/2024-06 TAG-BCAW Manual F-1-23 
 

References 

Risk Assessment 

Books 

Follett, P.A., and J.J. Duan (eds.) 2000. Nontarget Effects of Biological 

Control. Kluwer Academic Publishers. 316 pp. 

Londsdale, W.M., D.T. Briese, and J.M. Cullen. 2001. “Risk analysis and weed 

biocontrol.” Evaluating Indirect Effects of Biological Control. Wallingford, 

UK: CABI Publishing 185-210. 

NRC National Research Council. 1983. Risk Assessment in the Federal 

Government: Understanding the Process. National Academy Press: 

Washington, D.C. 192 pp. 

U.S. EPA. “Guidelines for Ecological Risk Assessment.” U.S. Environmental 

Protection Agency, Risk Assessment Forum, Washington, DC. EPA/630/R095/ 

002F, 1998. 

Websites 

“Decision Support Tools,” USDA National Invasive Species Information 

System, accessed March 21, 2014. 

“Guidelines for Ecological Risk Assessment,” U.S. Environmental Protection 

Agency, Risk Assessment Forum, Washington, DC, EPA/630/R095/002F, 

1998. 

“Noxious Weeds Program Risk Assessments,” United States Department of 

Agriculture, Animal and Plant Health Inspection Service, last modified April 

6, 2021. 

“Review of the National (Australian) Weed Risk Assessment System,” 

National (Australian) Weed Risk Assessment System Review Group, August 

2, 2006. 

F-1-24 TAG-BCAW Manual 04/2024-06 
 

 

 References 

Testing Methodology for Biological Control 

Testing Methodology for Biological Control 

Articles 

Barton, J. 2004. “How good are we at predicting the field host-range of fungal 

pathogens used for classical biological control of weeds?” Biological Control 

31: 99-122. 

Barton, J. 2012. “Predictability of pathogen host range in classical biological 

control of weeds: an update.” Biocontrol 57: 289-305. 

Berner, D. K. & Cavin, C.A. 2011. “Finalizing host range determination of a 

weed biological control pathogen with best linear unbiased predictors and 

damage assessment.” BioControl 57: 235-246. 

Briese, D.T. 1996. “Phylogeny: can it help us to understand host choice by 

biological weed control agents?” Proceedings of the IX International 

Symposium on Biological Control of Weeds, Stellenbosch, South Africa 63-70. 

Briese, D.T. 2005. “Translating host-specificity test results into the real world: 

The need to harmonize the yin and yang of current testing procedures.” 

Biological Control. 35: 208-214. 

Briese, D.T. and A. Walker. 2008. “Choosing the right plants to test: The hostspecificity of Longitarsus sp. (Coleoptera: Chrysomelidae) a potential 

biological control agent of Heliotropium amplexicaule.” Biological Control 

44: 271-285. 

Charudattan, R. 2005. “Ecological, practical, and political inputs into selection 

of weed targets: What makes a good biological control target?” Biological 

Control 35: 183-196. 

Clement, S. L. and M. Cristofaro. 1995. “Open-field tests in host specificity 

determination of insects for biological control of weeds.” Biocontrol Science 

and Technology 5: 395-406. 

Cook, R.J., W.L. Bruckart, J.R. Coulson, M.S. Goettel, R.A. Humber, R.D. 

Lumsden, J.V. Maddox, M.L. McManus, L. Moore, S.F. Meyer, et. al. 1996. 

“Safety of microorganisms intended for pest and plant disease control: A 

framework for scientific evaluation.” Biological Control 7(3): 333–351. 

Cullen, J.M. 1988. “Current problems in host-specificity screening.” 

Proceedings VII of the International Symposium of Biological Control of 

Weeds 27-36. 

04/2024-06 TAG-BCAW Manual F-1-25 
 

References 

Testing Methodology for Biological Control 

Davis, A.S., D.A. Landis, V. Nuzzo, B. Blossey, E. Gerber, and H. L. Hinz. 

2006. “Demographic Models Inform Selection of Biocontrol Agents for Garlic 

Mustard (Alliaria petiolata).” Ecological Applications 16(6): 2399-2410. 

Drea, John J., Jr. 1991. “The philosophy, procedures, and cost of developing a 

classical biological control of weeds project.” Natural Areas Journal 11(3): 

143–147. 

Dunn, P.H. 1976. “Shortcomings in classic tests of candidate insects for the 

biocontrol weeds.” Proceedings of the IV International Symposium on 

Biological Control of Weeds; Gainesville, FL51-56. 

Fowler, S.V., Q. Panter, S. Dodd, and R. Groenteman. 2012. “How can 

ecologists help practitioners minimize non-target effects in weed biocontrol?” 

Journal of Applied Ecology 49: 307-310. 

Gaskin, John F., Mare-Claude. Bon, Matthew J.W. Cock, Massimo Cristofaro, 

Alessio De Biase, Rose De Clerck-Floate, Carol A. Ellison, Harriet L. Hinz, 

Ruth A. Hufbauer, Mic H. Julien, and René Sforza. 2011. “Applying 

molecular-based approaches to classical biological control of weeds.” 

Biological Control 58: 1-21. 

Goolsby, J.A., R.D. van Klinken, and W.A. Palmer. 2006. “Maximising the 

contribution of native-range studies towards the identification and 

prioritisation of weed biocontrol agents.” Australian Journal of Entomology 

45(4): 276-286. 

Hasan, S., E.S. Delfosse, E. Aracil, and R.C. Lewis. 1992. “Host-specificity of 

Uromyces heliotropii, a fungal agent for the biological control of common 

heliotrop (Heliotropium europaeum) in Australia.” Annals of Applied Biology 

121: 697–705. 

Marohasy, J. 1998. “The design and interpretation of host-specificity tests for 

weed biological control with particular reference to insect behaviour.” 

Biocontrol News and Information 19(1): 13N-20N. 

McClay, A.S., and J.K. Balciunas. 2005. The role of pre-release efficacy 

assessment in selecting classical biological control agents for weeds-applying 

the Anna Karenina principle.” Biological Control 35: 197-207. 

McEvoy, P.B. 1996. “Host specificity and biological pest control.” Bioscience 

46: 401-405. 

F-1-26 TAG-BCAW Manual 04/2024-06 
 

 

 References 

Testing Methodology for Biological Control 

McEvoy, P.B., and E.M. Coombs. 1999. “Biological control of plant invaders: 

regional patterns, field experiments, and structured population models.” 

Ecological Applications 9: 387-4019: 

Morin, L., K.J. Evans, and A.W. Sheppard. 2006. “Selection of pathogen 

agents in weed biological control: critical issues and peculiarities in relation to 

arthropod agents.” Australian Journal of Entomology 45: 349-365. 

Pratt, P.D., M.B. Rayamajhi, T.D. Center, P.W. Tipping, and G.S. Wheeler. 

2009. “The ecological host range of an intentionally introduced herbivore: a 

comparison of predicted versus actual host use.” Biological Control 49: 46-

153. 

Raghu, S., and K. Dhileepan. 2005. “The value of simulating herbivory in 

selecting effective weed biological control agents.” Biological Control 34: 

265-273. 

Raghu, S., and R.D. van Klinken (eds). 2006. “Refining the ecological basis 

for agent selection in weed biological control.” Australian Journal of 

Entomology 45(4): 251-372. 

Raghu, S., J.R. Wilson, and K. Dhileepan. 2006. “Refining the process of agent 

selection through understanding plant demography and plant response to 

herbivory.” Australian Journal of Entomology 45: 308-316. 

Rector, B.G. 2008. “Molecular biology approaches to control of intractable 

weeds: New strategies and complements to existing biological practices.” 

Plant Science 175: 437-448. 

Schwarzländer, M., H.L. Hinz, and R. Wittenberg. 1996. “Oogenesis 

requirements and weed biological control: an essential part in host-range 

evaluation of insect agents or just wasted time?” Proceedings of the IX 

International Symposium on Biological Control of Weeds. Stellenbosch, South 

Africa: University of Cape Town. 79-85. 

Van Klinken, R.D. and S. Raghu. 2006. “A scientific approach to agent 

selection.” Australian Journal of Entomology 45: 253-258. 

Wapshere, A.J. 1974. “A strategy for evaluating the safety of organisms for 

biological weed control.” Annals of Applied Biology 77(2): 201–211. 

Withers, Toni M. 2003. “Examining the hierarchy threshold model in a 

no-choice feeding assay.” Entomologia Experimentalis et Applicata 91: 89-95. 

04/2024-06 TAG-BCAW Manual F-1-27 
 

References 

Testing Methodology for Biological Control 

Books 

Harley, K.L.S., and I.W. Forno. 1992. “Biology and Host-specificity of 

Biological Control Agents.” 27–36. In: Biological Control of Weeds: A 

Handbook for Practitioners and Students. Melbourne: Inkata Press. 74 pp. 

Van Driesche, R., T. Heard, A. McClay and R. Reardon. 2000. Host Specificity 

Testing of Exotic Arthropod Biological Control Agents - The Biological Basis 

for Improvement in Safety. USDA Forest Service. Forest Health Technology 

Enterprise Team Publication FHTET-99-1. 95 pp. 

Websites 

“BIREA - Biocontrol Information Resource for ERMA New Zealand 

Applicants,” Barratt B.I.P., Berndt L.A., Dodd S.L., Ferguson C.M., Hill R.L., 

Kean J.M., Teulon D.A.J. and Withers T.M., 2007. 

“Steps in a weed biological control program,” CSIRO, last modified October 

2011. 

F-1-28 TAG-BCAW Manual 04/2024-06 
Glossary 

TAG-BCAW 

Manual 

Introduction 

Use this glossary to find the meaning of specialized abbreviations, acronyms, 

terms, and words used in this manual. To locate where in the manual a given 

abbreviation, acronym, or term is mentioned, refer to the index. 

Definitions, Terms, and Abbreviations 

abiotic. Not pertaining to life or specific life conditions. 

APHIS. Animal and Plant Health Inspection Service, USDA. 

ARS. Agricultural Research Service, USDA. 

BCDC. Biological Control Documentation Center. 

BIA. Bureau of Indian Affairs, USDI. 

biological assessment (BA). Under the Endangered Species Act, the 

evaluation of a proposed action’s potential effects on listed and proposed 

species and designated/proposed critical habitat. 

biological control agent. A natural enemy, antagonist, or competitor, or other 

organism, used for pest control (FAO Glossary, 2010; ISPM 3:1995; revised 

ISPM 3:2005). 

biological evaluation (BE). A generic term for all other types of analyses 

(other than a biological assessment). If a listed species or critical habitat is 

likely to be affected, then the Agency must provide the Services (USFWS and 

NMFS) with an evaluation on the likely effects of the action. Often this 

information is referred to as the BE. 

biological control agents. Organisms that suppress or kill weedy plants 

without significantly injuring desirable plants (Andres, 1977). 

biotype. A group of organisms having the same genotype, but varying 

characteristics (e.g., strain differences or different physiological 

characteristics). The organisms sharing a specified genotype; also: the 

genotype shared or its distinguishing peculiarity. (www.merrian-webster.com/ 

dictionary). 

BLM. Bureau of Land Management, USDI. 

10/2023-05 TAG-BCAW Manual Glossary-1-1 
 

Glossary 

Definitions, Terms, and Abbreviations 

BR. Bureau of Reclamation, USDI. 

CBP. Customs and Border Protection 

CFR. Code of Federal Regulations 

COE. Army Corps of Engineers. 

conference. A process which involves informal discussions between a Federal 

Agency and the FWS/NMFS under Section 7(a)(4) of the Act (ESA) regarding 

the impact of an action on proposed species or proposed critical habitat and 

recommendations to minimize or avoid the adverse effects. 

confinement (of a regulated article). Application of official measures for 

regulated articles to prevent escape. [CPM, 2012] 

containment. Application of phytosanitary measures in and around an infested 

area to prevent spread of a pest (FAO, 1995) 

containment facility. Laboratory, greenhouse, or other type of secure 

installation designed to effectively prevent the escape or entry of organisms. 

(NAPPO 2012; RSPM 7: 2008; RSPM 12:2008; RSPM 22: 2011; RSPM 27: 

2007; RSPM 29: 2008) 

control (of a pest). Suppression, containment, or eradication of a pest 

population. [FAO, 1995] 

cryptic or sibling species. Sexually isolated populations with few or no 

tangible recognition characters to set them apart from the general species 

populations. 

CSREES. See NIFA. 

diapause. Period of arrested morphological development or suspended 

animation. 

DOD. Department of Defense. 

EA. environmental assessment. A concise, public document that briefly 

provides sufficient evidence and analysis for determining whether to prepare 

an environmental impact statement (EIS) or a finding of no significant impact 

(FONSI). 

ecosytem. A dynamic complex of plant, animal and micro-organism 

communities and their abiotic environment interacting as a functional unit. 

[ISPM 3:1995; revised ICPM, 2001] 

edaphic. Of or pertaining to soil, especially as it affects living organisms. 

Glossary-1-2 TAG-BCAW Manual 10/2023-05 
 

 

 Glossary

 Definitions, Terms, and Abbreviations 

EIS. Environmental Impact Statement. Serves as a broad, comprehensive 

reference evaluating anticipated environmental effects of alternative planned 

causes of action. APHIS prepares an EIS to meet its National Environmental 

Policy Act (NEPA) responsibilities. 

environmental impact. Effects on the agriculture, human health, and the 

environment. 

EPA. Environmental Protection Agency. 

ESA. Endangered Species Act. ESA as amended, was established in 1973 

providing the policies and procedures for protecting endangered and threatened 

species of fish, wildlife, and plants. An objective of ESA is to provide ways to 

conserve endangered and threatened species and their habitats. Also, ESA 

requires APHIS to consult with the U.S. Fish and Wildlife Service (FWS) to 

ensure that any anticipated program or action is not likely to jeopardize the 

survival of listed species, or is not likely to adversely modify or destroy their 

critical habitat. 

exotic species. Alien in origin, to the specific ecosystem under consideration. 

FACA. Federal Advisory Committee Act. TAG-BCAW meetings shall be 

conducted in compliance with the Federal Advisory Committee Act (FACA). 

FONSI. Finding of no Significant Impact. A public document that presents 

the reasons a proposed action would not have a significant impact on the 

environment, based on the results of an EA. 

FS. Forest Service, USDA. 

FWS. Fish and Wildlife Service, USDI. 

habitat. Part of an ecosystem with conditions in which an organism naturally 

occurs or can establish. [ICPM, 2005] 

host range. Species capable, under natural conditions, of sustaining a specific 

pest or other organism (FAO, 1990; revised ISPM 3:2005). 

host specificity testing. The process by which the species of plants at risk 

from a biological control agent in the field is determined. (NAPPO Glossary, 

1999) 

incidence (of a pest). Proportion or number of units in which a pest is present 

in a sample, consignment, field, or other defined population. [CPM, 2009] 

infestation (of a commodity). Presence in a commodity of a living pest of the 

plant or plant product concerned. Infestation includes infection [CEPM 1997; 

revised CEPM, 1999] 

10/2023-05 TAG-BCAW Manual Glossary-1-3 
 

Glossary 

Definitions, Terms, and Abbreviations 

IPPC. International Plant Protection Convention as deposited with FAO in 

Rome in 1951 and as subsequently amended. [FAO, 1990] 

ISPM. International Standard for Phytosanitary Measures [CEPM, 1996; 

revised. ICPM, 2001] 

isolates. Limited taxonomic collections of pathogens made from a specific 

location, and thus may not represent the entire genetic base of the species. 

material. Includes living organisms and toxins. 

monitoring. An official ongoing process to verify phytosanitary situations. 

[CEPM, 1996] 

morphometric. Relating to measurement of external form. 

NAPPO. North American Plant Protection Organization. International 

organization consisting of representatives from Canada, Mexico, and the 

United States. 

NEPA. National Environmental Policy Act. Congress enacted NEPA in 1969 

to ensure that Federal agencies assess the impact of potential environmental 

consequences before undertaking major programs or projects. Detailed 

information on the NEPA process is contained in “Regulations for 

Implementing the Procedural Provisions of the National Environmental Policy 

Act,” 40 CFR Parts 1500–1508. 

NIFA. National Institute of Food and Agriculture. Formerly CSREES 

(Cooperative State Research, Education, and Extension Service.) 

NPS. National Park Service, USDI. 

NMFS. National Marine Fisheries Service. 

NRCS. Natural Resources Conservation Service, USDA. 

natural enemy. An organism which lives at the expense of another organism 

in its area of origin and which may help to limit the population of that 

organism. This includes parasitoids, parasites, predators, phytophagous 

organisms, and pathogens. [ISPM 3:1995; revised ISPM 3:2005] 

official. Established, authorized, or performed by a national plant protection 

organization. [FAO, 1990] 

organism. Any biotic entity capable of reproduction or replication in its 

naturally occurring state. [ISPM 3:1995; revised ISPM 3:2005] 

parasite. An organism which lives on or in a larger organism, feeding upon it. 

[ISPM 3:1995] 

Glossary-1-4 TAG-BCAW Manual 10/2023-05 
 

 

 Glossary

 Definitions, Terms, and Abbreviations 

parasitoid. An insect parasitic only in its immature stages, killing its host in 

the process of development, and free living as an adult [ISPM 3:1995] 

pathogen. Micro-organism causing disease [ISPM 3:1995] 

pest. Any species, strain or biotype of plant, animal or pathogenic agent 

injurious to plants or plant products. Note: In the IPPC, plant pest is sometimes 

used for the term pest [FAO, 1990; revised FAO 1995; IPPC, 1997; revised 

CPM, 2012] 

petition. A formal, written application to a regulatory Agency seeking 

approval to release an exotic biological control agent. [NAPPO Glossary, 

1999] 

phytophagous. Organisms that eat plants. 

planting. Any operation for the placing of plants in a growing medium, or by 

grafting or similar operations, to ensure their subsequent growth, reproduction, 

or propagation. [FAO, 1990; revised CEPM, 1999] 

plants. Living plants. 

polyphagous. Feeding on or utilizing a variety of plants. 

positive control. Where the target is present at every step in the test process 

(i.e., treatment in which you would expect a positive response). 

PPD. Policy and Program Development. 

PPQ. Plant Protection and Quarantine. 

quarantine. Official confinement of regulated articles for observation and 

research or for further inspection, testing or treatment. [FAO 1990; revised 

FAO, 1995; CEPM 1999] 

release. (into the environment) Intentional liberation of an organism into the 

environment. [ISPM 3:1995] 

replicate . Replication of an experimental condition so that the variability 

associated with the phenomenon can be estimated. 

reference specimen. Specimen, from a population of a specific organism, 

observed and accessible for the purpose of identification, verification, or 

comparison. [ISPM 3:2005; revised CPM 2009] 

seeds. A commodity class for seeds for planting or intended for planting and 

not for consumption or processing. [FAO, 1990; revised ICPM, 2001] 

10/2023-05 TAG-BCAW Manual Glossary-1-5 
 

Glossary 

Definitions, Terms, and Abbreviations 

suppression. The application of phytosanitary measures in an infested area to 

reduct pest populations [FAO, 1995; revised CEPM, 1999] 

spread. (of a pest) Expansion of the geographical distribution of a pest within 

an area [FAO, 1995] 

standard operation procedure (SOP). . Codified best laboratory practices for 

handling biological control agents in quarantine or containment. (NAPPO 

2012: NAPPO Glossary, 1999) 

SPRO. State Plant Regulatory Official. Contact information for these officials 

can be found on the National Plant Board Web site. There is also a list of these 

officials in the Postentry Quarantine Manual. 

survey. An official procedure conducted over a defined period of time to 

determine the characteristics of a pest population or to determine which 

species occur in an area. [FAO, 1990; revised CEPM, 1996] 

take. To harm, harass, pursue, hunt, shoot, wound, kill, trap, capture, or 

collect or attempt to engage in any of these activities. 

test. Official examination, other than visual, to determine if pests are present 

or to identify pests. [FAO, 1990] 

test plant list. A representative list of plant species that will be subjected to 

host specificity tests. (Drea, 1991, p. 144) 

USDA. United States Department of Agriculture. 

USDC. United States Department of Commerce. 

USDI. United States Department of the Interior. 

USGS. United States Geological Survey, USDI. 

voucher specimens. A series of individuals from a specific population 

deposited in the National Collection(s) of the country. (NAPPO 2012; RSPM 

19: 2012; RSPM 27:2007). 

Glossary-1-6 TAG-BCAW Manual 10/2023-05 
TAG-BCAW 

Manual 

Index 

Numerics 

16 U.S.C. 1451 et. seq. 1-1-3 

16 U.S.C. 1531 1-1-3, 3-2-2 

42 U.S.C. 4321 1-1-3, 3-2-2 

50 CFR §402.08 6-1-3 

50 CFR §402.14 6-1-4 

50 CFR 402.13 6-1-3 

50 CFR Part 402 6-1-1 

64 CFR 6184 1-1-3 

64 FR 6183 3-2-2 

7 CFR 330.200 2-1-3, 3-2-3 

7 CFR 330.201 through 330.203 3-2-5 

7 U.S.C. 7701 1-1-3, 1-1-4 

A 

additional comments 

cover letter for 5-4-3 

TAG-BCAW members sending for 5-2-2 

TAG-BCAW members sending test plant lists 

for 5-4-3 

addresses 

PPQ Manuals Unit 1-1-9 

TAG-BCAW Executive Secretary 5-2-17, 5-4-

17, B-1-4 

TAG-BCAW membership A-1-1 

U.S. FWS Regional Offices D-1-1–D-1-2 

advice 2-1-3, 3-2-2 

Agricultural Research Service (ARS) 1-1-4 

perspective 2-3-3 

TAG-BCAW member A-1-1 

TAG-BCAW membership 2-2-5 

taxonomic institution F-1-8 

Technical Bulletin 1616 F-1-6 

Agriculture and Agri-Food Canada (AAFC) 

biological control of weeds 2-1-1 

cooperating 1-1-4 

perspective 2-3-10 

TAG-BCAW member A-1-2 

taxonomic institution F-1-8 

analysis 

biological control agents of weeds 4-1-3 

DNA 5-1-9 

experimental methodology and 5-1-11 

mixed model 4-4-3 

NEPA 2-1-3–2-1-4 

Animal and Plant Health Inspection Service 

(APHIS) 1-1-4 

TAG-BCAW membership 2-2-5 

annual meetings 

TAG-BCAW 2-2-4 

TAG-BCAW Executive Secretary duties 2-2-3 

APHIS 

Section 7 requirements 6-1-2 

APHIS Form 2000 B-1-10 

APHIS regulations 3-2-5 

APHIS-PPQ 

determination with USFWS or NMFS 

consultation 3-2-6 

recommendations from TAG-BCAW to 2-1-3 

APHIS-PPQ Pest Permitting Branch 2-3-2, 3-2-2, B-1-12 

approaches 

Agricultural Research Service (ARS) 2-3-3 

evaluation checklist 5-2-13 

identification and characterization 4-2-4 

research use 5-2-4 

taxonomic 4-2-4 

approval process 

National Plant Board 2-3-9 

Army Corps of Engineers (COE) 2-3-9 

perspective 2-3-9 

TAG-BCAW Chair A-1-2 

TAG-BCAW history 2-1-2 

TAG-BCAW membership 2-2-5 

TAG-BCAW review 2-4-2 

arthropods 

field testing 4-3-7 

oviposition testing 4-3-6 

assessing risk 2-1-4 

B 

biological assessment (BA) 

designation of non-Federal representative 6-

1-3 

document 6-2-1 

elements of 3-2-7 

guidelines 6-2-1 

information to include 6-2-2 

may affect, likely to adversely affect 

determination 6-2-5 

prepared by APHIS 3-2-7 

purpose 6-2-1 

Section 7 consultation requirement 3-2-7 

USFWS review 3-2-7 

biological control 2-1-1, 2-3-2 

Agricultural Research Service (ARS) 2-3-3 

APHIS authority 3-2-1 

APHIS-PPQ-CPHST 2-3-2 

Army Corps of Engineers (COE) 2-3-9 

Bureau of Indian Affairs 2-3-5 

Bureau of Land Management (BLM) 2-3-5 

Bureau of Reclamation (BR) 2-3-6 

Environmental Protection Agency (EPA) 2-3-9 

Fish and Wildlife Service (FWS) 2-3-7 

Forest Service (FS) 2-3-3 

Mexico 2-3-10 

A 

B 

C 

D 

E 

F 

G 

H 

I 

J 

K 

L 

M 

N 

O 

P 

Q 

R 

S 

T 

U 

V 

W 

X 

Y 

Z 

10/2023-05 TAG-BCAW Manual Index-1-1 
Index 

National Park Service (NPS) 2-3-7 

National Plant Board 2-3-9 

practice of 4-1-1 

reference collections 4-2-8 

weed management option 4-1-2 

Weed Science Society of America 2-3-9 

Biological Control Agent Release Proposal 

(BCARP) 2-3-6 

biological control agents 

authority to regulate importation and release 

2-1-3 

permit for removal from containment 3-2-6 

Plant Protection Act 1-1-3 

proposed environmental release and 

consultation with Tribal 

Governments 3-2-8 

risk analysis 4-1-3 

biological control organisms 2-3-2, 3-2-3 

Biological Control Release Record 2-3-6 

biological evaluation (BE) 6-2-1 

biologically relevant phenological stages 4-3-4 

biotypes 4-2-4, 4-4-3 

Bureau of Indian Affairs (BIA) 

cooperating agency 1-1-4 

perspective 2-3-5 

TAG-BCAW member A-1-1 

TAG-BCAW membership 2-2-5 

Bureau of Land Management (BLM) 1-1-4 

cooperating 1-1-4 

perspective 2-3-5 

Subcommittee on Biological Control of Weeds 

2-1-2 

TAG-BCAW membership 2-2-5 

Bureau of Reclamation (BR) 

cooperating agency 1-1-4 

perspective 2-3-6 

Subcommittee on Biological Control of Weeds 

2-1-2 

TAG-BCAW member A-1-3 

TAG-BCAW membership 2-2-6 

C 

Canada 5-1-3 

Agriculture and Agri-Food Canada 1-1-4, 2-3-

10 

historical informal review 2-1-2 

NAPPO Standard C-1-1 

national specimen collections 4-2-8 

TAG-BCAW contact A-1-2 

taxonomic institutions in F-1-8 

Web site for Committee on the Status of 

Endangered Wildlife in Canada F-1-

20 

candidate species 

threatened and endangered species 3-2-2 

characterization 4-2-1, 5-2-4 

charter 2-2-1 

classical biological control 2-1-1 

classification system 5-4-4 

classification systems 5-3-9, 5-4-3 

Coastal Zone Management Act 1-1-3 

comments 2-2-2, 2-2-6, 2-4-1, 3-2-2, 3-2-5, 3-2-

8, 5-2-2, 5-2-3, 5-2-8, 5-2-17, 5-3-3, 5-4-2, 5-4-

3, 5-4-17, 6-1-6, B-1-7 

compliance 

ESA Section 7 3-2-6 

concurrence letter 

may affect, not likely to adversely affect 3-2-7 

conflicts of interest 2-1-4 

consultation 

no effect on listed species or critical habitat 3-

2-6 

Consultation and Coordination with Indian Tribal 

Governments, EO 13175 3-2-8 

containment facilities 

inspection of 3-2-3 

live biological control organisms 3-2-3 

continued curation 

PPQ 526 Permit for 3-2-4 

continued movement 

colonies or cultures of organisms 3-2-4 

controls 4-4-7 

critical habitat 

proposed release no effect on designated 3-2-

6 

cryptic species 4-2-6, 5-1-8, 5-1-13, 5-2-11, 5-2-

14 

D 

diapause 4-2-5, 5-1-9 

directories 

Conservation Directory 5-3-8 

TAG-BCAW Membership Directory A-1-1 

U.S. Fish and Wildlife Service (FWS) Regional 

Offices D-1-1 

Directory of TAG Membership A-1-1 

disease 4-4-3 

diseases 4-4-1, 4-4-2, 4-4-3 

soil and susceptibility to 4-4-4 

symptomatology 4-4-5 

techniques for rating 4-4-4 

District of Columbia 

interstate movement of live biological control 

organisms 3-2-3 

documentation flow 3-1-1 

duties 

TAG-BCAW Chair 2-2-3 

TAG-BCAW Executive Secretary 2-2-3 

TAG-BCAW members 2-2-2 

USDA-APHIS-PPQ 2-2-4 

E 

early involvement 2-1-3 

ecologically relevant phenological stages 4-3-4 

economic impacts 2-3-2 

ecosystems 

safeguarding 2-3-2 

endangered species 

Mexico 2-3-10 

Endangered Species Act (ESA) 

affect release 3-2-2 

compliance 3-2-6, 6-2-1 

FWS perspective 2-3-7 

purpose 6-1-1 

regulatory authority 1-1-3 

Section 7 6-1-2 

TAG-BCAW mission consideration of 2-2-1 

A 

B 

C 

D 

E 

F 

G 

H 

I 

J 

K 

L 

M 

N 

O 

P 

Q 

R 

S 

T 

U 

V 

W 

X 

Y 

Z 

Index-1-2 TAG-BCAW Manual 05/2022-03 
Index 

TAG-BCAW Section 7 compliance with 6-1-6 

Environment Protection Agency (EPA) 

perspective 2-3-9 

environmental assessment (EA) 3-2-7 

element of biological assessment (BA) 3-2-7 

for NEPA compliance 3-2-7 

potential environmental impacts 5-1-15 

environmental compliance 3-2-8 

environmental impact statement (EIS) 3-2-7, 3-2-8, 6-2-1 

environmental impacts 5-1-13, 5-1-15 

aim to minimize 2-3-2 

comment sheet review 2-4-2 

Compliance with NEPA 3-2-7 

petition evaluation checklist 5-2-16 

Environmental Protection Agency (EPA) 

TAG-BCAW membership 2-2-5 

EO 13175, Consultation and Coordination with Indian Tribal Governments 3-2-8 

EPA-Office of Pesticide Programs A-1-3 

evaluation checklist 

field release of biological control agents of 

weeds 5-2-5 

Executive Order 13112 1-1-3 

F 

facilitator TAG-BCAW 2-1-3 

Federal 

lists of threatened and endangered species 3-

2-2 

Federal action Agency 

designation of non-Federal representative 6-

1-3 

Federal Actions to Address Environmental Justice 

in Minority Populations and Low-income Populations 3-2-2 

Federal Advisory Committee Act (FACA) 2-1-3, 2-

2-5 

Federal Agencies 

ESA Section 7 requirements 6-1-2 

Federal Insecticide, Fungicide, and Rodenticide Act 

2-3-6 

field cages 

testing candidate agents 4-3-4 

field-collected material 4-3-3 

final decisions 2-1-4 

Finding of No Significant Impact (FONSI) 3-2-7 

Fish and Wildlife Service (FWS) 1-1-4 

Fish and Wildlife Service (USFWS) 

contacting for guidance 3-2-2 

Food Quality Protection Act of 1996 2-3-6 

Forest Service 

TAG-BCAW membership 2-2-5 

Forest Service (FS) 1-1-4 

TAG-BCAW member A-1-1 

formal consultation 

APHIS with USFWS 3-2-7 

functional analysis 4-2-5 

G 

genetically-engineered plant pests B-1-10 

genetically-engineered plants B-1-10 

H 

host specificity testing 

advice 2-1-3 

proposed plant list 2-2-2 

host testing phase 

contacting USFWS 3-2-2 

I 

identifying biological control agents 4-2-5 

Importation 

live biological control organisms into U.S. and 

Territories 3-2-3 

importation 

biological control agent authority 2-1-3 

regulated by APHIS 2-1-1 

informal consultation 3-2-6, 6-1-3 

Interagency Cooperation 6-1-2 

interagency cooperation 6-1-1 

interstate movement 

live biological control organisms 3-2-3 

invasive species 

executive order 1-1-3 

L 

laboratory colonies 4-3-2, 4-3-3 

live biological control organisms 

permits 3-2-3 

live regulated organisms 

in containment beyond expiration of 526 

permit 3-2-4 

M 

may affect and is likely to adversely affect 

formal consultation requirement 3-2-7 

Memorandum of Understanding (MOU) 2-3-6 

Mexico 2-2-5, 4-2-8 

cover page 5-1-3 

NAPPO Standard C-1-1 

national collections 4-2-8 

SAGARPA-SENASIA-DGSV 1-1-4 

TAG-BCAW 2-2-3 

TAG-BCAW directory A-1-3 

taxonomic institution F-1-8 

movement 

live biological control organisms from 

containment facilities 3-2-3 

multiple choice tests 4-3-4 

N 

NAPPO RSPM No. 7 4-2-8 

national collection required deposit 4-2-8 

national collections 4-2-8, 4-2-9 

National Environmental Policy Act (NEPA) 

compliance 3-2-6 

environmental assessment (EA) 3-2-7 

regulatory authority 1-1-3 

National Environmental Policy Act (NEPA) analysis 

2-1-3 

National Institute of Food and Agriculture (NIFA) 1-

1-4 

TAG-BCAW membership 2-2-5 

National Marine Fisheries Service (NMFS) 

consultation 3-2-6 

National Park Service (NPS) 1-1-4 

TAG-BCAW membership 2-2-6 

National Plant Board 

perspective 2-3-9 

A 

B 

C 

D 

E 

F 

G 

H 

I 

J 

K 

L 

M 

N 

O 

P 

Q 

R 

S 

T 

U 

V 

W 

X 

Y 

Z 

05/2022-03 TAG-BCAW Manual Index-1-3 
Index 

TAG-BCAW cooperating organization 1-1-4 

TAG-BCAW member A-1-2 

TAG-BCAW membership 2-2-6 

Native American Tribes 

release of proposed biological control agents 

of weeds 3-2-8 

Native Americans 2-3-5 

Natural Resource Conservation Service 1-1-4 

TAG-BCAW membership 2-2-5 

NEPA analysis 2-1-4 

no-choice tests 4-3-4 

non-active TAG-BCAW members 2-2-6 

nonindigenous biological control agents 2-2-1 

contacting TAG-BCAW early 2-2-2 

nonindigenous organisms 2-2-2 

APHIS permitting process 3-2-1 

nonindigenous pests 2-3-2 

nonindigenous species 

US FWS perspective 2-3-7 

nonindigenous weed biological control organisms 

permit issuance for 3-2-6 

non-indigenous weeds 2-3-2 

O 

open field tests 4-3-4 

oviposition testing 4-3-6 

oviposition tests 4-3-7 

P 

permit expiration 

live biological control organisms in 

containment facilities 3-2-3 

permits 

requirements for APHIS 3-2-3 

Pest Permitting Branch 2-3-2, 3-2-2, B-1-12 

petitioners 

action recommendation prior to permit 

application 2-1-4 

APHIS permitting process 3-2-2 

application for 526 permit to remove biological 

control organism from containment 

3-2-6 

contacting USWFS 3-2-2 

ESA Section 7 process participation 6-1-2 

receipt of APHIS letter support release 3-2-6 

petitions 

first-time field release 2-2-2 

petitions for release 

review and evaluation of submitted 2-3-1 

plant classification system E-1-1 

plant diseases 2-3-2 

Plant Protection Act of 2000 (PPA) 

regulatory authority 1-1-3 

potential petitioners 2-1-3 

PPQ 526 Permit 

continued curation 3-2-4 

for importation of live biological control 

organisms 3-2-3 

for removal from containment 3-2-4 

renewal for continued movement interstate 

movement renewal 3-2-4 

PPQ 526 permit 

retention of regulated organisms in 

containment 3-2-4 

PPQ 526 permits 

guidance and instructions for obtaining 3-2-3 

proposed biological control agents 

final testing 4-3-4 

proposed biological control agents of weeds 

TAG-BCAW recommendations 2-1-4 

proposed environmental release 

weed biological control agents 3-2-8 

proposed plant list 

test plant list for host specificity testing 2-2-2 

proposed test plant list 3-2-2 

R 

recommendations 

TAG-BCAW 2-1-4 

TAG-BCAW to APHIS 2-1-3 

reference collection 

individuals from released population 4-2-8 

regulatory agencies 2-1-4 

release 

biological control agents 2-1-4 

biological control agents authority 2-1-3 

biological control agents into environment. 3-

2-6 

non-indigenous biological control agent 2-2-2 

regulated by APHIS 2-1-1 

research community 2-1-4 

researchers 

early involvement of TAG-BCAW 2-1-3 

input from USFWS or NMFS 3-2-6 

retention 

containment beyond 526 permit expiration 3-

2-4 

live biological control organisms in 

containment facilities 3-2-3 

review process 3-2-2 

risk analysis 

biological control agents 4-1-3 

S 

safeguarding American agriculture 2-3-2 

SAGARPA-SENASIA-DGSV 1-1-4 

perspective Mexico 2-3-10 

science-based link 2-1-4 

screening tests 

test plant list species 4-3-4 

Section 7 6-1-1, 6-1-2 

biological assessment (BA) 

prepared by APHIS 3-2-7 

species 

targeted for first-time release 2-2-2 

State 

interstate movement of live biological control 

organisms 3-2-3 

States 

lists of threatened and endangered species 3-

2-2 

Subcommittee on Biological Control of Weeds 2-1-

2 

T 

TAG-BCAW Chair 

member involvement assessment 2-2-6 

TAG-BCAW final recommendation 3-1-1 

term 2-1-3 

A 

B 

C 

D 

E 

F 

G 

H 

I 

J 

K 

L 

M 

N 

O 

P 

Q 

R 

S 

T 

U 

V 

W 

X 

Y 

Z 

Index-1-4 TAG-BCAW Manual 05/2022-03 
Index 

TAG-BCAW Executive Secretary 2-1-3 

duties 2-2-3 

petition responses 2-2-2 

TAG-BCAW Reviewer’s Comment Sheet 5-2-

17 

TAG-BCAW meetings 2-2-5 

annual meeting 2-2-4 

duties of Chair 2-2-3 

duties of Executive Secretary 2-2-3 

duties of members 2-2-2 

TAG-BCAW members 

representative of respective organization 2-2-

6 

TAG-BCAW recommendations 2-1-3, 2-3-1 

Technical Advisory Group for Biological Control 

Agents of Weeds (TAG-BCAW) 2-1-3–2-1-4 

charter 2-2-1, 2-2-2 

techniques 4-2-5 

territory 

permit for interstate movement of live 

biological control organisms 3-2-3 

test plant lists 

alteration of previously approved 5-1-11 

commenting on proposed 3-2-2 

distribution to TAG-BCAW 2-2-3 

flow chart 3-1-2 

no-choice testing 4-3-5 

not reviewed prior to petition 5-1-11 

previously prepared and reviewed by TAGBCAW 5-1-11 

receipt acknowledgment 2-2-4 

review due date assignment 2-2-3 

submitting proposed list early 3-2-2 

TAG-BCAW advise related to 2-1-3 

TAG-BCAW Chair review 2-4-3 

TAG-BCAW Manual reference guide for 1-1-1 

TAG-BCAW member review and evaluation 2-

3-1 

TAG-BCAW review 2-1-4, 2-2-2 

target weed information on 5-1-5 

threatened and endangered species 3-2-2 

test plants 

conducting tests on relevant phenological 

stages of 4-3-4 

inclusion of 2-1-3, 2-2-2 

threated and endangered species lists 

TAG-BCAW reviewers and researchers 

review of 3-2-2 

tribal governments 

contact with Federally-recognized 3-2-8 

tribal implications 3-2-8 

tribal officials 

APHIS consultation and collaboration with 3-

2-8 

U 

U.S. Army Corps of Engineers 1-1-4 

TAG-BCAW 2-2-5 

U.S. Environmental Protection Agency (EPA) 1-1-4 

U.S. Fish and Wildlife Service (USFWS) 

TAG-BCAW member A-1-2 

TAG-BCAW membership 2-2-6 

U.S. Geological Survey (USGS) 1-1-4 

TAG-BCAW membership 2-2-6 

U.S. Territories 

permits for importation of live biological control 

organisms 3-2-3 

United States 

cover page 5-1-3 

National collections for specimens 4-2-9 

permits for importation of live biological control 

organisms 3-2-3 

United States Department of Agriculture (USDA) 

cooperating organization 1-1-4 

United States Department of Defense (USDOD) 

cooperating organization 1-1-4 

United States Department of Interior (USDI) 1-1-4 

USDA Forest Service (FS) 

TAG-BCAW member A-1-1 

USDA-APHIS 

TAG Executive Secretary A-1-1 

TAG-BCAW member A-1-3 

USDI Bureau of Reclamation (BR) 

TAG-BCAW member A-1-3 

USDI-National Park Service A-1-2 

USFWS consultations 3-2-6 

W 

weed biological control organism 

permit for removal from containment 3-2-6 

Weed Science Society of America (WSSA) 

cooperating agency 1-1-4 

perspective 2-3-9 

TAG-BCAW membership 2-2-6 

Weed Science Society of America Representative 

A-1-3 

weeds 

classical biological control 2-1-1 

Working Group on Biological Control of Weeds 2-1-

2 

A 

B 

C 

D 

E 

F 

G 

H 

I 

J 

K 

L 

M 

N 

O 

P 

Q 

R 

S 

T 

U 

V 

W 

X 

Y 

Z 

05/2022-03 TAG-BCAW Manual Index-1-5 
Index 

A 

B 

C 

D 

E 

F 

G 

H 

I 

J 

K 

L 

M 

N 

O 

P 

Q 

R 

S 

T 

U 

V 

W 

X 

Y 

Z 

Index-1-6 TAG-BCAW Manual 05/2022-03